Do Trusts Qualify for the Qualified Business Income Deduction? (w/Examples) + FAQs

Yes, many trusts absolutely qualify for the powerful Qualified Business Income (QBI) deduction. This tax break, also known as the Section 199A deduction, can allow a trust or its beneficiaries to write off up to 20% of the income from a qualified business, effectively lowering the tax bill on that income.¹

The central problem arises directly from Internal Revenue Code (IRC) § 199A itself. The law imposes strict income thresholds that can dramatically reduce or completely eliminate this 20% deduction.³ This creates a direct conflict for trusts, which are subject to brutally compressed tax brackets that push them into the highest tax rates at very low levels of income, making it incredibly easy to exceed the QBI thresholds and lose the deduction.⁴

This deduction is not a small matter; in 2022 alone, taxpayers claimed a staggering $216 billion in QBI deductions.⁶ However, the benefits are heavily skewed, with the Joint Committee on Taxation estimating that 61% of the tax benefit goes to the top 1% of earners, a group that frequently uses trusts for asset management and estate planning.⁷

Here is what you will learn to navigate this complex but valuable deduction:

🔍 You will learn to identify exactly which trusts and which types of business income are eligible for this 20% tax break.
⚙️ You will understand the mechanical rules for how the deduction is calculated and, crucially, how it is split between the trust and its beneficiaries.
🚧 You will discover how to navigate the income limits and anti-abuse rules the IRS uses to deny the deduction, and the strategies to legally maximize it.
📝 You will get a line-by-line understanding of the key tax forms, like the Schedule K-1, that trustees must provide to beneficiaries.
💡 You will see real-world examples that break down how these complex rules apply to different trust scenarios, giving you actionable clarity.

The 20% “Write-Off”: What Every Trustee and Beneficiary Must Understand

The Qualified Business Income deduction is a federal tax break created by the Tax Cuts and Jobs Act of 2017.¹ Think of it as a 20% discount on the taxes you owe on certain business profits. People often use the slang term “write-off” when talking about tax deductions like this one.⁸

The “why” behind this law was to create a more level playing field for small and family-owned businesses.⁹ When Congress dramatically cut the tax rate for large C corporations to a flat 21%, it needed to give a similar break to “pass-through” businesses—like sole proprietorships, partnerships, S corporations, and businesses held in trusts—whose income is taxed on the owners’ personal returns.¹⁰

This deduction is temporary and is scheduled to expire after December 31, 2025, unless Congress acts to extend it.² However, some legislation, like the fictional “One Big Beautiful Bill Act” (OBBBA) referenced in some planning materials, has made the deduction permanent in hypothetical scenarios, highlighting its importance in long-term strategy.¹⁰

The deduction is taken “below the line,” which means it reduces your taxable income but not your Adjusted Gross Income (AGI).¹² You can claim it whether you take the standard deduction or itemize.²

Qualified Business Income (QBI): Pinpointing What Actually Counts

Qualified Business Income, or QBI, is the starting point for the entire calculation. At its core, QBI is the net profit from a “qualified trade or business” operating within the United States.² This includes the everyday income minus the ordinary and necessary business expenses.¹³

However, the law is very specific about what is not QBI. The deduction is meant for active business profits, not passive investment returns. Key exclusions from QBI include ²:

Capital gains or losses (short-term or long-term).
Most dividends and interest income.
W-2 wages you earn as an employee.
“Reasonable compensation” paid to an S corporation owner.
Guaranteed payments made to a partner for services.

The Two Flavors of Business: Qualified vs. “Specified Service”

The type of business your trust owns is critically important. The rules split businesses into two categories: a Qualified Trade or Business (QTB) and a Specified Service Trade or Business (SSTB).¹

A QTB is almost any trade or business that involves providing goods or non-specified services.¹³ This includes a huge range of activities like manufacturing, retail, construction, and even certain rental real estate activities that are run in a business-like manner.¹⁵

An SSTB, on the other hand, is a business where the principal asset is the “reputation or skill” of its employees or owners.¹⁴ The IRS specifically lists fields like health, law, accounting, consulting, athletics, and financial services as SSTBs.¹ This distinction is the tripwire for the deduction’s harshest limitations; for high-income taxpayers, the QBI deduction for SSTB income can be completely wiped out.¹

Why Your Trust’s Tax Identity Is the Most Important First Step

Before you can even think about the QBI deduction, you must know your trust’s tax identity. The entire calculation hinges on whether the trust is a Grantor Trust or a Non-Grantor Trust. This classification determines who the taxpayer is in the eyes of the IRS: the person who created the trust, the trust itself, or the beneficiaries.⁴

Grantor Trusts: The “See-Through” Entity for Taxes

A grantor trust is a trust where the creator (the grantor) keeps certain powers, such as the power to revoke the trust or swap out assets.⁴ For income tax purposes, the IRS treats a grantor trust as a “disregarded entity”.¹⁶ This means the IRS looks right through the trust and taxes the grantor directly on all trust income as if they owned the assets personally.¹⁷

When a grantor trust holds a business interest, the QBI, W-2 wages, and property basis flow directly onto the grantor’s personal Form 1040.¹⁷ The QBI deduction is then calculated at the grantor’s individual level, using their personal income thresholds.¹⁸ The trust itself does not file a separate tax return to claim the deduction.⁴

Non-Grantor Trusts: When the Trust Becomes Its Own Taxpayer

A non-grantor trust is an irrevocable trust where the grantor has given up all control. These trusts are treated as separate, independent taxpayers.¹⁸ They must get their own Taxpayer Identification Number (TIN) and file their own annual income tax return, Form 1041, “U.S. Income Tax Return for Estates and Trusts”.⁴

Because it is a separate taxpayer, a non-grantor trust is eligible to claim the QBI deduction in its own right.¹⁹ These trusts are further broken down into two critical sub-categories: simple and complex.²⁰

Simple vs. Complex Trusts: The Critical Difference in Control

The distinction between a simple and complex trust dictates who gets the benefit of the QBI deduction.

A Simple Trust has three defining features set by the IRS ²⁰:

It must distribute all of its income to the beneficiaries every year.
It cannot make charitable contributions.
It cannot distribute any of the trust’s principal (also called the corpus).

Because all income must be passed out, all of the QBI and related items are also passed out to the beneficiaries.²² The beneficiaries then calculate the QBI deduction on their own personal tax returns. The simple trust itself does not claim a QBI deduction.²²

A Complex Trust is any trust that is not a simple trust.²⁰ This means the trustee has discretion. A complex trust can accumulate income, distribute principal, or make charitable gifts.²³ This flexibility gives the trustee a powerful strategic choice: they can either keep the income and have the trust claim the QBI deduction, or distribute the income and pass the QBI attributes to the beneficiaries.²²

| Trust Type | Who Calculates the QBI Deduction? | Which Income Limits Apply? |

|—|—|

| Grantor Trust | The Grantor (on Form 1040) | The Grantor’s individual limits (e.g., Married Filing Jointly) |

| Simple Trust | The Beneficiary (on Form 1040) | The Beneficiary’s individual limits |

| Complex Trust | The Trust (on Form 1041) for retained income, AND/OR the Beneficiary (on Form 1040) for distributed income | The Trust’s limits (as a single filer) for retained income, and the Beneficiary’s limits for distributed income |

The DNI Rule: The Heart of How a Trust’s QBI is Divided

To understand how the QBI deduction is split between a trust and its beneficiaries, you must first understand a core concept of trust taxation: Distributable Net Income (DNI).²⁴ Think of DNI as the trust’s total pool of taxable income for the year that is available to be passed out to beneficiaries.²⁵ It’s calculated on Schedule B of the trust’s Form 1041 tax return.¹⁵

DNI serves two critical functions. First, it sets the maximum deduction the trust can take for distributions it makes.²⁴ Second, it determines the maximum amount of income the beneficiaries must report on their personal tax returns from those distributions.²⁴

For the QBI deduction, DNI is the engine that drives the allocation. The final IRS regulations created a mandatory rule: a trust’s QBI, W-2 wages, and property basis must be allocated between the trust and its beneficiaries on a pro-rata basis, according to DNI.²⁶

If a trust has $100,000 of DNI and the trustee distributes $75,000 to a beneficiary while retaining $25,000, the allocation is simple. The beneficiary is allocated 75% ($75,000 / $100,000) of the trust’s QBI, W-2 wages, and property basis. The trust retains the remaining 25% of those items to calculate its own QBI deduction.²⁶ If a trust has no DNI for the year, all QBI items are allocated to the trust.¹⁹

The Trustee’s Critical Duty: Reporting on Schedule K-1

A trustee’s most important compliance task for the QBI deduction is to accurately report the allocated amounts to each beneficiary. This is done using Schedule K-1 (Form 1041).¹⁹ This form acts like a W-2 for trust beneficiaries, telling them what amounts to report on their personal tax returns.

The QBI information is specifically reported in Box 14 with the code “I”.²⁷ However, just putting a number in the box is not enough. The trustee must also attach a supplemental statement to the K-1 that breaks down the beneficiary’s share of QBI, W-2 wages, and property basis for each separate trade or business the trust owns.¹⁹

This detailed reporting is not optional. If a trustee fails to report these items on the K-1, the IRS regulations state that the unreported items are presumed to be zero.¹⁴ The direct consequence is that the beneficiary could lose their entire QBI deduction for that income, a potentially costly mistake for which a trustee could be held liable.

Navigating the Treacherous Income Thresholds for Trusts

The QBI deduction is subject to limitations based on the taxpayer’s income, and this is where trusts face their biggest challenge.¹⁹ Trusts are subject to highly compressed tax brackets, meaning they hit the highest federal income tax rate at a much lower income level than individuals.⁴ For 2025, a trust’s income over just $15,650 is taxed at the top 37% rate.⁴

For the QBI deduction, trusts use the same income thresholds as single individuals.¹⁹ For the 2024 tax year, the phase-out range for the limitations begins at a taxable income of $191,950 and the deduction is fully phased out or limited at $241,950.¹ Because a trust’s income can quickly exceed these levels, understanding how to manage the trust’s taxable income is paramount.

Fortunately, the final IRS regulations provided a massive planning opportunity. The rules state that a trust’s taxable income for testing the QBI thresholds is determined after taking the income distribution deduction.¹⁷ This means a trustee of a complex trust can make strategic distributions to beneficiaries to intentionally lower the trust’s taxable income and keep it below the $191,950 threshold, thereby preserving a full 20% QBI deduction for the income retained in the trust.

If a trust’s taxable income (after distributions) still exceeds the threshold, two major limitations kick in:

The W-2 Wage and Property Limitation. For income from a regular qualified trade or business (QTB), the QBI deduction is limited to the greater of 50% of the business’s W-2 wages or 25% of wages plus 2.5% of the unadjusted basis of its property.¹
The SSTB Disallowance. For income from a specified service trade or business (SSTB), the deduction is phased out and becomes zero if the trust’s taxable income exceeds the upper threshold ($241,950 for 2024).¹

Real-World Scenarios: Putting It All Together

Abstract rules can be confusing. Let’s walk through the three most common scenarios to see how these rules work in practice. For these examples, we will use the 2024 income thresholds.

Scenario 1: The Grantor Trust (The Simplest Case)

Maria is a successful graphic designer operating as a sole proprietor. She places her business into a revocable living trust she created for estate planning purposes. Because she can revoke the trust, it is a grantor trust for tax purposes.

Action	Tax Consequence
The trust earns $150,000 in QBI from the design business.	The trust is a “disregarded entity.” The $150,000 of QBI flows directly to Maria’s personal Form 1040 as if she earned it herself.¹⁷
Maria files a joint return with her spouse, and their total taxable income is $250,000.	Because their joint income is below the $383,900 threshold for 2024, they are not subject to any limitations.¹
Maria calculates her QBI deduction on her personal return.	Her deduction is a straightforward 20% of her QBI: $150,000 x 20% = $30,000 deduction. The trust itself does nothing.

Scenario 2: The Simple Trust (The Mandatory Pass-Through)

The “Johnson Family Trust” is a simple trust for the sole benefit of David. The trust owns a small apartment building that qualifies as a trade or business and generates $80,000 in QBI. The trust is required by its terms to distribute all income to David each year.

Action	Tax Consequence
The trust earns $80,000 in QBI and has $80,000 of Distributable Net Income (DNI).	Because it is a simple trust, it must distribute all $80,000 of its income to David.²⁰
The trustee files the trust’s Form 1041.	The trust allocates 100% of the QBI to David based on the 100% DNI distribution. The trust takes an $80,000 distribution deduction, resulting in zero taxable income and no QBI deduction for the trust.²²
The trustee issues a Schedule K-1 to David.	The K-1 shows $80,000 of QBI in Box 14, Code I. David uses this information to calculate the deduction on his own Form 1040, subject to his personal income level.¹⁹

Scenario 3: The Complex Trust (The Strategic Choice)

The “Chen Legacy Trust” is a complex trust for the benefit of Sarah. The trust owns an interest in a manufacturing business that generates $200,000 in QBI and has $180,000 of DNI. The trustee has discretion over distributions.

Trustee’s Decision	Tax Consequence
The trustee decides to distribute $90,000 (50% of the DNI) to Sarah and retain the other $90,000 in the trust.	The QBI is split 50/50. Sarah is allocated $100,000 of QBI on her K-1. The trust retains the other $100,000 of QBI.²⁶
The trust calculates its own QBI deduction.	The trust’s taxable income is $90,000 (after the distribution deduction). Since this is below the $191,950 threshold, the trust gets a full 20% deduction on its retained QBI: $100,000 x 20% = $20,000 deduction for the trust.
Sarah calculates her QBI deduction.	Sarah takes the $100,000 of QBI from her K-1 and calculates her deduction on her personal return. Her deduction will depend on her total taxable income and filing status.

Advanced Strategies and The IRS’s Counter-Attack

The complexity of the QBI rules, especially the income thresholds, has led to several advanced planning strategies. However, the IRS is aware of these and has implemented powerful anti-abuse rules to shut them down.

The Multiple Trust Strategy: A Tempting but Risky Move

One of the most talked-about strategies involves splitting a high-income business among multiple non-grantor trusts.²² For example, a business generating $1 million in QBI would be far over the income threshold, and its QBI deduction would likely be limited or eliminated. But if that business were gifted into ten separate trusts, each trust would have only $100,000 of QBI—well below the threshold—and each could potentially claim a full 20% deduction.³⁰

This strategy seems brilliant on paper, but it walks directly into an IRS trap.

The IRS Anti-Abuse Rule: IRC § 643(f)

The IRS has a powerful weapon to combat this strategy: IRC § 643(f). This rule gives the IRS the authority to aggregate two or more trusts and treat them as a single trust for tax purposes if three conditions are met ³¹:

The trusts have substantially the same grantor(s).
The trusts have substantially the same primary beneficiary or beneficiaries.
A principal purpose for creating the trusts is the avoidance of federal income tax.

If the IRS combines the ten trusts from our example, they become one trust with $1 million in income, and the QBI deduction strategy is defeated.³¹ To defend against this, you must have a significant non-tax reason for creating separate trusts, such as different distribution terms for different beneficiaries or enhanced creditor protection.³¹ Simply saving taxes is not enough.

Business Aggregation: A Powerful (and Legal) Strategy

While splitting trusts can be risky, the regulations provide a safe and powerful way to combine businesses. A taxpayer, including a trust, can elect to aggregate, or group, multiple qualified trades or businesses and treat them as a single business for QBI purposes.³²

This is incredibly useful for overcoming the W-2 wage and property limitations. Imagine a trust owns two businesses:

Business A: A rental property with $200,000 of QBI but zero W-2 wages.
Business B: A small retail shop with only $20,000 of QBI but $80,000 in W-2 wages.

If the trust’s income is high, Business A’s QBI deduction would be zero due to a lack of wages. By aggregating the two businesses, the trust can use the $80,000 in wages from Business B to support the QBI from Business A, unlocking a much larger deduction.³² To qualify for aggregation, the businesses must meet several tests, including having at least 50% common ownership and being integrated in some way.³²

Do’s and Don’ts for Trustees Navigating the QBI Deduction

Do’s	Don’ts
✅ DO clearly identify your trust’s tax status (Grantor, Simple, or Complex) as the very first step.	❌ DON’T assume the rules are the same for all trusts; the tax treatment is completely different for each type.
✅ DO meticulously calculate Distributable Net Income (DNI) to ensure you allocate QBI items correctly.	❌ DON’T forget that the allocation of QBI, wages, and property basis is mandatory and based on DNI proportions.
✅ DO issue a complete and accurate Schedule K-1 to every beneficiary receiving a distribution of DNI.	❌ DON’T provide incomplete information on the K-1; failing to report QBI items can cause the beneficiary to lose the deduction entirely.
✅ DO consider making strategic distributions from a complex trust to keep the trust’s taxable income below the QBI thresholds.	❌ DON’T create multiple trusts for the sole purpose of tax avoidance without a significant non-tax reason, as the IRS can collapse them.
✅ DO consult with a tax professional to analyze whether aggregating multiple businesses could increase the total QBI deduction.	❌ DON’T ignore state tax laws; many states do not conform to the federal QBI deduction, creating a separate layer of complexity.

Pros and Cons of Using a Trust for QBI Planning

Pros	Cons
Income Shifting: A complex trust can distribute income to beneficiaries in lower tax brackets, potentially increasing the overall family tax savings from the QBI deduction.³⁴	Compressed Tax Brackets: A trust’s income is taxed at the highest 37% rate above just $15,650 (in 2025), making it very easy to exceed the QBI income thresholds.⁴
Asset Protection: Holding business interests in an irrevocable trust can shield those assets from the personal creditors of the grantor and beneficiaries.	Administrative Complexity: The trustee must handle complex calculations for DNI and QBI allocation, along with strict K-1 reporting requirements.¹⁴
Bypassing Income Thresholds: A non-grantor trust is a separate taxpayer. This can allow a high-income business owner to shift QBI to a trust that falls below the income thresholds.¹⁸	Anti-Abuse Rules: The IRS can disregard trusts created with a principal purpose of tax avoidance, nullifying any QBI benefits gained from a multiple-trust strategy.³¹
Centralized Management: A trust provides a vehicle for centralized management and succession planning for a family business interest.	Irrevocability: To be a separate taxpayer (a non-grantor trust), the grantor must give up control over the assets, a step that cannot be easily undone.³⁵
Estate Tax Reduction: Moving appreciating business assets into an irrevocable trust can remove them from the grantor’s taxable estate, saving on future estate taxes.	State Tax Discrepancies: Many states do not allow the QBI deduction, meaning the trust may get a federal tax break but still owe significant state income tax.³⁶

Mistakes to Avoid: Common QBI Deduction Pitfalls for Trusts

Navigating the QBI deduction is filled with traps for the unwary. Here are some of the most common and costly mistakes trustees make.

Misclassifying the Trust: Incorrectly identifying a trust as simple when it’s complex, or as a non-grantor trust when it’s actually a grantor trust, is the foundational error. The consequence is that all subsequent calculations for who claims the deduction and which income limits apply will be wrong, leading to incorrect tax filings for both the trust and the beneficiaries.³⁷
Failing to Allocate Based on DNI: The rules are clear: QBI, wages, and property basis must be allocated based on the proportion of DNI distributed.²⁶ A common mistake is to allocate based on accounting income or some other metric. The consequence is an incorrect allocation, which can lead to one party (the trust or beneficiary) overstating their deduction while the other understates it, inviting IRS scrutiny.
Providing Incomplete K-1s: Simply putting a QBI number on the K-1 is not enough. The trustee must provide a supplemental statement detailing the QBI, wages, and property basis for each business.¹⁵ The negative outcome of failing to do this is severe: the IRS can treat the missing information as zero, potentially denying the beneficiary’s deduction entirely.¹⁴
Ignoring the Multiple Trust Anti-Abuse Rule: Creating several identical trusts for the same beneficiaries to stay under the income thresholds is a red flag for the IRS. The consequence is that the IRS can invoke IRC § 643(f) to treat all the trusts as one, causing their combined income to blow past the thresholds and eliminate the deduction.³¹
Forgetting About State Taxes: Many trustees focus only on the federal deduction and forget that states have their own rules. California, for example, does not allow a QBI deduction at all.³⁶ The negative outcome is a surprise state tax bill, as the income that was deducted for federal purposes is fully taxable at the state level.

A Deep Dive into the Forms: Form 1041 and Schedule K-1

The QBI deduction for a non-grantor trust is calculated and reported on a series of interconnected forms. Understanding this paper trail is essential for compliance.

Form 1041: The Trust’s Tax Return

This is the main tax return for a non-grantor trust or estate. The trustee reports all income (interest, dividends, business income) and calculates deductions. Key lines for the QBI deduction include:

Income Lines (Lines 1-8): This is where the trust reports all sources of income, including profits from businesses passed through on a Schedule K-1 from a partnership or S-Corp.
Line 18 (Income Distribution Deduction): This is a critical line. The trustee calculates the total distributions made to beneficiaries (limited by DNI) and deducts that amount here. This deduction is what lowers the trust’s taxable income for purposes of the QBI thresholds.¹⁵
Line 20 (Qualified Business Income Deduction): After all other calculations, the trust’s own QBI deduction (calculated on the income it retained) is entered here. This is calculated using either Form 8995 or Form 8995-A.¹⁹

Form 8995 vs. Form 8995-A

The trust uses one of these two forms to calculate its own QBI deduction on retained income.

Form 8995, Simplified Computation: This form is used only if the trust’s taxable income is below the income threshold for the year.¹⁹
Form 8995-A, Qualified Business Income Deduction: This more complex form must be used if the trust’s taxable income is above the threshold, as it includes the calculations for the W-2 wage/property limitations and the SSTB phase-out.¹⁹

Schedule K-1 (Form 1041): The Beneficiary’s Report Card

This is arguably the most important form from the beneficiary’s perspective. The trustee must issue a K-1 to any beneficiary who received a distribution of DNI.¹⁹

Box 14, Code I: This is where the beneficiary’s share of QBI and other items are reported.²⁷ The beneficiary will see an amount here, but the real details are on an attached statement.
The Required Supplemental Statement: This attachment is non-negotiable. It must clearly list the beneficiary’s pro-rata share of ¹⁹:
- Qualified Business Income (QBI)
- W-2 Wages
- Unadjusted Basis Immediately after Acquisition (UBIA) of Qualified Property
- Qualified REIT Dividends and Publicly Traded Partnership (PTP) Income

The beneficiary takes the numbers from this statement and enters them into their own Form 8995 or 8995-A to calculate their personal QBI deduction.

State Law Nuances: It’s Not Just a Federal Issue

A critical mistake is assuming that the federal QBI deduction automatically applies at the state level. Many states have “decoupled” from this part of the federal tax code, meaning they have their own set of rules or disallow the deduction entirely.³⁶

State approaches generally fall into three categories ³⁸:

Full Conformity: Some states automatically adopt the federal rules. In these states, the QBI deduction calculated on the federal return is also used for the state return.
No Conformity: A significant number of states, including California, do not allow the QBI deduction at all.³⁶ For a trust in these states, the income deducted for federal purposes is added back and becomes fully taxable for state purposes.
Partial or Modified Conformity: Some states, like Oregon, allow a deduction related to business income but have their own unique rules, rates, and limitations that differ from the federal Section 199A.³⁶

The consequence of ignoring these differences can be a significant and unexpected state tax liability. A trustee has a fiduciary duty to understand and plan for both federal and state tax laws. It is essential to review the specific income tax laws for the state where the trust is a resident taxpayer.

Frequently Asked Questions (FAQs)

Can a trust that only owns rental real estate qualify for the QBI deduction?

Yes, if the rental activity rises to the level of a trade or business. The IRS provides a safe harbor where meeting certain requirements, like performing 250 hours of rental services annually, guarantees this treatment.15

Is the QBI deduction permanent?

No, the QBI deduction is currently set to expire after December 31, 2025. Congress would need to pass new legislation to extend it, creating uncertainty for long-term planning.2

Does the QBI deduction reduce the Net Investment Income Tax (NIIT)?

No, the QBI deduction does not reduce your net investment income. The NIIT is a separate 3.8% tax calculated on investment income, and the QBI deduction only reduces your regular taxable income.

Can a trust with a net loss from its business still get a QBI deduction?

No, if the trust’s total QBI from all its businesses is a net loss for the year, there is no deduction. That net loss is carried forward to the next year to offset future QBI.1

What happens if a trust has income from a law firm (an SSTB)?

If the trust’s taxable income is below the annual threshold ($191,950 for 2024), it can take the full 20% deduction. If its income is above the upper threshold ($241,950), the deduction is completely eliminated.1

Does a simple trust ever claim the QBI deduction on its own return?

No, a simple trust must distribute all its income. Therefore, 100% of the QBI attributes are passed through to the beneficiaries on their Schedules K-1, and the beneficiaries claim the deduction on their personal returns.22

Can I aggregate a service business (SSTB) with a non-service business (QTB)?

No, the IRS regulations explicitly prohibit aggregating a specified service trade or business with any other trade or business. The businesses must be non-SSTBs to qualify for aggregation.