When Congress enacted the Omnibus Budget Reconciliation Act of 1993 it imposed incremental intra-period predicate factual requirements on the inter-period rental real property trade or business activity conclusive presumption. In that legislation, however, Congress did not impose incremental predicate factual requirements on the strictly intra-period Section 469(h)(1) participation conclusive presumption. Since the 1993 legislation, it appears the IRS, the Secretary of the Treasury, taxpayers, and professionals alike continue to confuse whether Congress's 1993 action imposing the incremental Section 469(c)(7)(B)(i) and (ii) intra-period predicate factual requirements qualified the activity or participation conclusive presumption, or both. This webcast resolves that confusion.
The Activity Conclusive Presumption
The Participation Conclusive Presumption
Noncorporate Lessor Activity Conclusive Presumptions
Section 469(c)(7)(B)'s Rental Real Property Trade or Business Activity Qualifying Predicate Factual Requirements
**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].
Delivery Method: Individual webcast
CPE Credit: Taxes
Program Level: Intermediate