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.

Public Finance Activities, Tax Deductions & Exemptions, Accounting and auditing, Contracts, Real estate, Tax deductions, Real property, Rents (Property), Loss deductions, Passive activity (Taxation)

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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.

Tax Management, Tax accounting, Tax planning, Tax elections

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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.

Small business, One-person corporations, One person corporations

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