TAM : when is a rental activity "insubstantial" for purposes of grouping activities under the passive activity loss rules?
Article Abstract:
The author discusses IRS Technical Advice Memorandum 200014010 which provides guidance concerning the tax treatment of rental activity losses under IRC section 469 of an S corporation. The IRS disallowed the offsetting of business activity income with the passive rental activity losses.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2000
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Trio of rulings offer conversion opportunities
Article Abstract:
The author discusses IRS Letter Rulings 200007011, 1999942009, and 199947034 which concern business form conversions and check-the-box elections. The three rulings provide guidance on allowable conversions which result in state or transfer tax benefits.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2000
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LTR 200125090 and tax planning opportunities under check-the-box and the SBJPA
Article Abstract:
The author discusses tax planning opportunities for small businesses under IRS check-the-box regulations and the Small Business Job Protection Act of 1996.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2001
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