GOP Tax Bill - W2 wage limit vs. employment income

[Colin B.]

Trying to make sense of the tax bill - the last minute "Trump/Corker" clause seems to be a big handout in that we will be able to at minimum, take 2.5% of our capital basis as an extra deduction against NOI no matter what we pay in W2 wages, or what our incomes are.

It seems there is also the possibility of taking 20% of our NOI if that value is higher - very likely for higher cashflow properties. However, this has some restrictions. There is an income limit of $315K for a married couple where this starts to phase out unless the pass-through is paying significant W2 wages. This was intended to prevent people from reclassifying all of their income in a pass-through to take this deduction.

Below the $315K limit, it seems anyone can take the 20% for any pass-through business.  It's understanding what this limit applies to and includes that I'm stumped on.

1. Does this income limit phase-out of the 20% NOI deduction even apply to rental property whether you are passive or actively managing with no W2 income from the rental property? Or does it only apply to the designated "service" pass-throughs in which case forget question #2...

2. Assuming rental pass-throughs are subject to the $315K limit... To keep the math simple, suppose you are a couple with $500K in normal salaried employment wage income from another source. Meanwhile, you have rentals with NOI = $100K. And you pay $0 W2 wages in the pass-through rental business. Does your non-pass-through income count towards the $315K income limit to block taking the 20% of pass-through NOI deduction? Or are the income and W2 payments examined on a business-by-business basis to determine each pass-through's eligibility for the deduction? This is a question I cannot find answered clearly, and even after finding and reading much of the tax bill, it's not clear to me.