QBI & Pass-Through Entities

QBI Loss Carryforward Guide for Foreign-Owned Businesses (2025-2026)

10 min readArticle
Filing path

How to approach this

A source-based path from understanding the rule to filing and recordkeeping.

  1. Determine the requirement

    Confirm whether and how the rule applies to you.

  2. Identify the forms

    Map the requirement to the specific IRS forms involved.

  3. Prepare and file

    Complete the forms accurately and submit on time.

  4. Retain records

    Keep documentation supporting every figure you report.

Key formsIRS guidance

Key Takeaways

  • A negative QBI year generally creates a QBI carryforward to the next year.
  • The QBI carryforward rule is separate from ordinary loss deductibility rules.
  • The carryforward can still matter even after the original business ends.
  • Suspended losses must be tracked separately until they are actually allowed for taxable income purposes.

A negative QBI year does not disappear just because the business survives

The 2025 Instructions for Form 8995 say that if a taxpayer has a qualified business net loss for the year, the loss is carried forward to the next year. The instructions are clear that this carryforward does not change the deductibility of the loss for other parts of the Code. It is a section 199A tracking rule, not a replacement for the ordinary loss rules.

That distinction matters because some founders assume a deductible business loss and a QBI loss are the same thing. They are related, but they are not the same calculation.

The carryforward can survive even if the business later closes

The Form 8995 instructions also say the amount carried forward offsets QBI in later years regardless of whether the trade or business that generated the loss is still in existence. That is a surprisingly important detail for founders who have wound down one venture and started another.

The practical effect is that an old QBI loss can still suppress a later-year section 199A deduction even after the original business is gone.

Suspended losses require an extra layer of tracking

The instructions explain that losses or deductions suspended by other Code provisions are not treated as qualified losses in the year they are suspended. Instead, the qualified portion is taken into account later when the suspended amount becomes deductible for taxable income purposes. That means a clean QBI file has to track both current-year loss carryforwards and delayed-suspension mechanics.

Without that tracking, later-year QBI calculations are often wrong even when the main tax return looks fine.

Frequently Asked Questions

Does a QBI loss carryforward vanish if I shut down the business that created it?

No. The Form 8995 instructions say the carryforward offsets later QBI regardless of whether the original trade or business is still in existence.

Are suspended losses automatically part of QBI in the year they arise?

No. The instructions say suspended losses are taken into account for QBI only when the allowed portion becomes deductible in computing taxable income.

If I have a net QBI loss, can I still have a QBI deduction?

Generally no, unless qualified REIT dividends or qualified PTP income change the result under the section 199A rules.

QBIqualified business incomepass-throughsection 199A

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