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Section 469(c)(7) Procedure, Practice, and Regulatory Implications

 
 Thursday, Dec. 20, 2018 from 12:00 pm to 3:00 pm
 Online
 
3.0
19 / 2-31652
Registration is Open
VSCPA Members
$99.00 Regular Registration
Nonmembers
$129.00 Regular Registration
Designed For:
*Recognize the Tax Court’s March 2014 Aragona Trust decision should be correctly accorded retroactive treatment *Recognize transition practices correctly involve amending all open-year returns that had reported Section 469(c)(7) rental real property trade or business activities inconsistent with
Prerequisite:

This webcast is an intermediate continuing education webcast.
It is assumed the webcast participant has successfully completed the ACPEN/BPN webcast, "Section 469's Activity and Participation Conclusive Presumptions"

My October 2016 Journal of Taxation paper, "Section 469's Activity and Participation Conclusive Presumptions," makes clear the Tax Court's March 2014 Aragona Trust decision distilled previously confused rental real property trade or business activity and material participation distinctions. This paper concludes Aragona Trust is procedurally retroactive, outlines transition practices, and calls for regulatory changes.

Syllabus

Lesson 1.

Introduction

Lesson 2.

Aragona Trust is Procedurally Retroactive

Lesson 3.

Pragmatic Transitioning Practices

Lesson 4.

The Call for Regulatory Change

Lesson 5.

Conclusion

**Please Note: If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to [email protected].

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