Final passive activity regs. include favorable and unfavorable changes for taxpayers
Article Abstract:
The final regulations released by the IRS to replace the proposed IRC section 469 passive activity regulations include changes and clarifications of positions taken in the proposed regulations. The final regulations allow the combination of active business income and passive activity losses when they are within the same appropriate economic unit and the owners own the rental activity in the same proportion. The final regulations also allow certain combinations of real property rental activities and personal property rental activities.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1995
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Recent developments affecting cancellation of debt income, bankruptcy estates, and investment interest
Article Abstract:
The IRS Revenue Ruling 92-92 states that income from cancellation of debt (COD) may be considered passive income under IRC Section 469. The rules used to characterize interest expense on the discharged debt are used to determine whether the COD income is from a passive activity. The COD income is allocated to the same expenditure as that to which the discharged debt is allocated. Thus, if the discharged debt was allocated to a passive activity, the COD income is likewise passive.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1993
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Passive activities: coordination of sections 469(g) and 163
Article Abstract:
The IRS has issued regulations to coordinate passive losses under section 469(g) with debt reallocations under section 163. On Feb 27, 1992 the House passed a bill giving 469 relief to real estate rentals. Other IRS actions include Revenue Ruling 92-29 on tax preparation expenses, Letter Ruling 9215013 on S corporation stock and Technical Advice Memorandum 9209004 on interest deductions for debt to buy a work cooperative's stock.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1992
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