Final regs. clarify but do not fundamentally alter rental real estate activity rules
Article Abstract:
Final regulations released by the IRS in Dec 1995 under IRC section 469(c)(7) address some of the concerns raised by the proposed regulations but fail to respond to many of the concerns of commentators. The regulations govern the treatment of rental real estate activities engaged in by qualified taxpayers as well as providing aggregation election guidance. The final regulations do not change the general rule that investors cannot aggregate rental passive activities with nonrental passive activities for purposes of the material participation test.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1996
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Proposed regulations allow aggregation of limited partner interests
Article Abstract:
The aggregation election under IRC section 469(c)(7) is available for taxpayers whose rental real estate activity includes participation as a limited partner. Aggregation of separate activities often helps taxpayers qualify for the material participation exception to the rule that losses from real estate rental activities are always passive losses. Limited partnership activities can be aggregated with other activities, but the aggregated activities will then be treated like a limited partnership.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1995
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Recent developments and legislative outlook
Article Abstract:
Partners of a mining partnership who are not materially involved in the relevant activity may be recipients of passive income from the partnership. Despite the fact that these partners count the income as part of their portfolio income, it must also be considered part of their passive activity gross income. This income may be offset with passive activity deductions.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1993
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