Activity Grouping: The Impact of Recent Developments

Since the passive activity loss rules of Sec. 469 were enacted in 1986, practitioners have wrestled with the concept. They are often faced with an arduous task in obtaining the relevant facts to ensure their clients’ compliance with the rules. Clients’ participation levels in various activities usually require annual examination, and material participation can sometimes be difficult to discern, especially with LLC members or limited liability partnership partners. The activity grouping rules of Regs. Sec. 1.469-4, which were Continue reading “Activity Grouping: The Impact of Recent Developments”