Washington tax watch
Article Abstract:
The Final Regulations pertaining to the application of passive loss regulations of rental real estate owned through partnerships are discussed. Section 469(c)(7) modifies the general rule treating rental activities as passive activities. It provides that the general rule is not applicable to rental real estate activities of persons participating in the real estate business. A qualifying taxpayer must have performed more than half of personal services in real property trades and must have rendered more than 750 hours of service during the tax year.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1996
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Final Anti-Abuse Regulation Expanded and Clarified, but Uncertainties Remain
Article Abstract:
The Department of Treasury's Final Anti-Abuse Regulation disallowing partnerships from reducing partners' aggregate federal tax liability substantially as to be inconsistent with the intent of Subchapter K, is studied. and criticised.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1995
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New Final Passive "Activity" Regulations Tighten Partial Disposition Rule
Article Abstract:
The article examines regulations and tax planning under the new final passive "activity" regulations under Section 469 of the U.S. Internal Revenue Code which limits a partner's deduction of partnership losses.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1995
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