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Section 199A and You

What if one retirement-plan contribution could do more than defer tax? For some high-income service-business owners, it can also reopen the door to a deduction they had completely lost.

The 2026 Case

Meet Dr. Anson Jones

Dr. Anson Jones reviewing documents in his modern orthopedic spine clinic office

In this case study, Dr. Jones owns and operates his private medical practice as an S corporation. He is very successful, but, like most business owners, feels he is getting killed on taxes. Where did things go wrong?

Profession
Orthopedic spine surgeon
Filing Status
Married filing jointly
Age
52
Entity
S corporation
Taxes Paid
$139,769
QBI Deduction
$0
The Problem

Dr. Jones Reported $0 on Line 13a.

The Qualified Business Income (QBI) deduction was intended to be the big break for small business owners. A brand new 20% deduction of their business income. Created in 2017, made permanent in 2025. For Dr. Ansom, that would be an $82,000 deduction from taxable income! So why did his tax professional put $0 instead? Because it has a catch.

If the reputation or skill of one or more employees or owners is its principal asset, your business is likely a Specified Service Trade or Business (SSTB), and your 20% deduction now has to undergo an income test. If Dr. Ansom owned a construction business instead of a medical practice, for example, this wouldn't have happened.

QBI Deduction$0
QBI Deduction$82,000

Should Dr. Jones hang up his stethoscope and put on a hard hat then? Probably not. It's not easy to build a $1,000,000 business. More so, with a better understanding of QBI and proper planning, he can recover part of the deduction.

The Catch

A Specified Service Trade or Business (SSTB)

Let's examine what happened to Dr. Jones' QBI deduction and see if your personal case is similar.

The SSTB Income Test

DeductionSingleMarried Filing Jointly
Full Deduction

Full SSTB QBI may be considered

$201,750 or less$403,500 or less
Partial Deduction

SSTB eligibility fades out

$201,750–$276,750$403,500–$553,500
No Deduction

SSTB QBI is excluded

More than $276,750More than $553,500

Now we see the problem and the catch that is causing it. Dr. Jones success, while marvelous, is taking away the deduction that was meant to be the hand up for small business owners. But, what if he could get it back with proper planning?

Dr. Anson Jones' Clinic
S Corporation Pass-Through Income$410,000
Owner W-2 Income+ $200,000
Household Income$610,000
Standard Deduction− $32,200
Taxable Income Before Section 199A$577,800
versus Full SSTB Phaseout$553,500
QBI Deduction$0
The First Solution

A 401(k) Plan Is Enough to Reopen the Door.

Anson can combine the 2026 employee deferral and employer contribution for a modeled owner contribution of $72,000. Because he has employees, the illustration also includes a 3% employer contribution of $8,700 for his team, bringing the total current income reduction to $80,700.

Before planning$577,800Above full SSTB phaseout
401(k) plan−$80,700Owner and staff contributions
After planning$497,100Back inside the phase-in range

The plan contribution reduces both taxable income and QBI. Even so, getting taxable income back inside the SSTB range is valuable because part of the remaining QBI becomes eligible again.

The Payoff

This Is More Than Tax Deferral.

The retirement contribution creates the first deduction. The lower taxable income then restores a second deduction under Section 199A. That second layer does not require Anson to place another dollar into the retirement account.

Layer one$80,700

Retirement-plan deduction

The modeled plan combines $72,000 for Anson with $8,700 of employer contributions for his five employees.

Layer two$26,606

New Section 199A deduction

Crossing back into the SSTB phase-in range restores a deduction that was unavailable before the plan contribution.

Combined$107,306

Modeled current deduction impact

The two deductions work together, although only the retirement contribution places money into a tax-deferred account.

After PlanningAmount
Taxable income before retirement planning$577,800
Employee deferral($24,500)
Employer contribution for Anson($47,500)
Employer contribution for five employees($8,700)
Taxable income before Section 199A$497,100
Restored Section 199A deduction($26,606)
Taxable income after Section 199A$470,494
The planning insight

The $80,700 retirement-plan deduction includes contributions for Anson and his employees. Taxable distributions may follow. The modeled $26,606 Section 199A deduction is different. It is a new current deduction created by moving back into eligibility.

Calculation Detail

How Anson Arrives at $577,800.

This supporting ledger preserves the before-planning calculation without interrupting the opening explanation.

Before PlanningAmount
Gross income$1,000,000
Staff payroll($290,000)
Other business expenses, including all employer payroll taxes($100,000)
Owner W-2 wage($200,000)
S corporation pass-through income$410,000
Owner W-2 income reported on Form 1040$200,000
Household income before the standard deduction$610,000
2026 Married Filing Jointly (MFJ) standard deduction($32,200)
Taxable income before Section 199A$577,800
Modeled Section 199A deduction$0
Bonus Section

The Next Level

A properly designed 401(k) plan solves Anson's first problem. The practice may be able to go further by placing his spouse on payroll and pairing 401(k) allocations with a cash balance pension plan. His five employees remain part of every design.

Illustrative practice profit$1,000,000

before owner wages, employer payroll taxes, and retirement-plan funding

Practice profit before owner wages and plan funding
$1,000,000
Anson and spouse W-2 wages
($375,000)
Employer payroll taxes
($28,688)
401(k) funding for both spouses
Up to $160,000
Illustrative cash balance funding
$400,000
Modeled taxable income before Section 199A
About $378,000
Result
Below the $403,500 threshold

Two participants create more planning capacity.

In this illustration, Anson and his spouse each receive W-2 compensation and participate in the plan. Their combined 401(k) funding can reach $160,000 if both are age 50 or older and otherwise eligible.

A cash balance plan then adds an illustrative $400,000 of employer funding. The exact amount is not a statutory election: an actuary must calculate it from ages, compensation, promised benefits, plan assets, and design.

Modeled together, the wages and plan funding bring household taxable income to roughly $378,000—below the $403,500 SSTB threshold—even though the practice began with $1 million.

Appendix

Details behind the Illustrations.

These supporting details are available for readers who want to examine the employee census, modeling assumptions, and source material behind the case study.

The Problem

How the $82,000 Comparison Was Calculated

Gross Income$1,000,000
Staff Payroll− $290,000
Other Business Expenses, Including All Employer Payroll Taxes− $100,000
Owner W-2 Wage− $200,000
Modeled Qualified Business Income$410,000
QBI Deduction Rate× 20%
Theoretical QBI Deduction$82,000
The Catch

Who is an SSTB?

The IRS identifies specific service fields and financial-market activities.

A narrower rule also covers certain income from endorsements, licensing a person's identity, and appearances at events or in media.

Service Fields
  • Health
  • Law
  • Accounting
  • Actuarial Science
  • Performing Arts
  • Consulting
  • Athletics
  • Financial Services
Financial-Market Activities
  • Brokerage Services
  • Investing & Investment Management
  • Trading
  • Dealing in Securities, Partnership Interests, or Commodities
The Practice Team

Employee Census

Dr. Jones cannot use an owner-only retirement plan. Any plan design must account for the people who help operate his practice, including Cat, a nurse practitioner and clinical provider.

Combined staff payroll$290,000
EmployeeRoleAgeW-2 Compensation
CatNurse practitioner45$100,000
AnaPractice employee40$55,000
RonPractice employee35$50,000
EvaPractice employee30$45,000
SamPractice employee25$40,000
Model Notes

Methodology & Limits

  • The first case models an orthopedic spine surgeon, age 52, operating a private medical practice through an S corporation and filing jointly with no other material household income, capital gain, or itemized deductions. The $100,000 of other business expenses includes all employer payroll taxes, including those attributable to Dr. Jones's W-2 wage.
  • The calculation uses the 2026 $403,500 MFJ Section 199A threshold, the $553,500 end of the SSTB phase-in range, and the $32,200 standard deduction.
  • The $200,000 W-2 wage is an assumption, not a reasonable-compensation opinion. A wage this low may not be defensible for the services of a successful orthopedic spine surgeon.
  • The 401(k) illustration uses a $24,500 employee deferral plus a $47,500 employer contribution for Anson and a modeled 3% employer contribution of $8,700 for his five employees. No catch-up contribution is included. Eligibility, plan documents, testing, compensation, and participation can change the required cost.
  • The restored QBI deduction applies the SSTB applicable percentage and the wage/property limitation phase-in. Displayed amounts are rounded; calculations use unrounded figures.
  • The bonus case is a planning-capacity illustration, not a contribution quote. Cash balance funding requires actuarial design and may create ongoing funding, administration, coverage, and nondiscrimination obligations.

This article is educational and uses fictitious facts. It is not individual tax, legal, accounting, actuarial, or investment advice. Retirement-plan deductions and Section 199A eligibility should be coordinated with a certified public accountant (CPA), attorney, plan administrator, and actuary as appropriate.

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