Farm CPA Report

Farm CPA Report

Still Waiting on USDA Guidance on Entity Payment Limits

Last weeks release did not address the new entity payment limits

Paul Neiffer's avatar
Paul Neiffer
Jan 14, 2026
∙ Paid
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Photo by d z on Unsplash

Last week’s Federal Register release by USDA was only on ARC, PLC, Base Acres Increase and Dairy Margin Coverage.

We are still waiting for guidance from USDA on how to implement the new Qualified Pass-Through Entity changes. Under pre-OBBBA, only a general partnership or joint venture was allowed payment limits based on the number of owners.

OBBBA then changed the rules to reflect that any LLC not taxed as a C corporation, any S corporation or any entity elected to be taxed as a partnership would also see payment limits based on owners instead of only having one payment limit.

However, we still need guidance to determine the following:

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