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Section 469's Activity and Participation Conclusive Presumptions

 
 Wednesday, Nov. 28, 2018 from 2:00 pm to 5:00 pm
 Online
 
3.0
19 / 2-31503
Registration is Open
VSCPA Members
$99.00 Regular Registration
Nonmembers
$129.00 Regular Registration
Designed For:
*Recognize how to correctly distinguish conclusive presumption ultimate facts from conclusive presumption predicate facts *Recognize that trade or business activity conclusive presumptions are correctly considered inter-period because both historic and prospective facts and factors are taken into
Prerequisite:

This webcast is an intermediate continuing education webcast.
It is assumed the webcast participant has fundamental knowledge of tax issues, material participation definitions, passive activity losses, section 469(c)(7) rental real estate trade of business activity issues, noncorportate lessor secton 179 100% depreciation expense issues.

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.

Syllabus

Lesson 1.

Introduction

Lesson 2.

Conclusive Presumptions

Lesson 3.

The Activity Conclusive Presumption

Lesson 4.

The Participation Conclusive Presumption

Lesson 5.

Noncorporate Lessor Activity Conclusive Presumptions

Lesson 6.

Section 469(c)(7)(B)'s Rental Real Property Trade or Business Activity Qualifying Predicate Factual Requirements

Lesson 7.

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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