How a High-Income Couple Restructured Their Assets Around the OBBBA's Permanent QBI Rules

Sam's List Editorial | 2026-06-06

How a High-Income Couple Restructured Their Assets Around the OBBBA's Permanent QBI Rules Tax planning built around a provision that was supposed to expire is planning that needs to be rebuilt. The OBBBA changed the expiration date for Section 199A's qualified business income deduction from December 31, 2025 to permanent. That's not a small adjustment — for high-income pass-through business owners, it changes which structural decisions make sense. This couple had made several of those decisions in anticipation of the sunset. When the sunset didn't come, Calculated Wealth rebuilt their financial plan from the ground up. The Clients: $750,000 in Combined Pass-Through Income, Planning Around a Deadline That Moved Both spouses owned businesses. Combined pass-through income was $750,000 per year. They had been working with an advisor and a CPA to plan around the QBI deduction's scheduled sunset at the end of 2025. That planning was sensible given what was known at the time. Strategies that look attractive when you get a 20% deduction on qualifying income look different when that deduction disappears. The couple had been positioning both their entities and their investment portfolio around the assumption that 2025 would be the last year of full QBI treatment. The OBBBA changed that assumption permanently. The deduction didn't sunset. It became a permanent feature of the tax code. When the law passed, Calculated Wealth initiated a full review of the couple's financial plan — not just the tax pieces, but the entity structure, the investment portfolio, and the long-term projections that underpinned every decision they had made in the prior three years. The Entity Structure Problem: A C-Corp That Made Sense Under the Old Rules One spouse ran a management consulting practice — a business that could be classified as a specified service trade or business (SSTB) under Section 199A. The SSTB classification matters because it determines how the QBI phase-out applies at high income levels. Under the pre-OBBBA rules, joint filers above the SSTB threshold faced a complete phase-out of the QBI deduction for specified service businesses. At $750,000 in combined income, this couple was well above the old threshold. Several years earlier, the spouse's consulting practice had been restructured as a C-corp. The decision made sense at the time: a C-corp is not a pass-through entity and is not subject to the SSTB QBI phase-out rules. The flat 21% corporate rate was attractive, and with the QBI deduction expected to sunset, locking in the corporate rate felt like the lower-risk...