| Title |
Author |
Type |
Date |
Words |
| The maze of real estate rentals. |
Hesse, Christopher W. |
|
Oct 1, 2020 |
4851 |
| Reality check: Virtual currency and its tax ramifications. |
Chandrasekera, Shehan |
|
Jul 1, 2018 |
2734 |
| CARRIED INTEREST AND BEYOND: THE NATURE OF PRIVATE EQUITY INVESTMENT AND ITS INTERNATIONAL TAX IMPLICATIONS. |
Kim, Young Ran Christine |
|
Mar 22, 2018 |
27819 |
| Mortgage broker is not a real estate professional. |
Kirk, David |
|
Jan 1, 2018 |
743 |
| Passive activity credits and recharacterized income. |
Hesse, Christopher W. |
|
Sep 1, 2017 |
2400 |
| Cleansing the PFIC taint: planning and pitfalls. |
Barragato, Charles A. |
|
Jun 1, 2017 |
3498 |
| Tax Court approves surgeon's reclassification of interest in surgical center as passive: despite K-1 reporting of income as for services, the taxpayer can net it against investment losses. |
Kebodeaux, Keith |
|
May 1, 2017 |
840 |
| New regulations for subpart F and CFC investment in U.S. property. |
Islam, Adnan |
|
Apr 1, 2017 |
2074 |
| Disposing of passive activities. |
Ellentuck, Albert B. |
|
Apr 1, 2017 |
2453 |
| Navigating the real estate professional rules. |
Nitti, Tony |
|
Mar 1, 2017 |
9933 |
| Tax Court takes a scalpel to surgeon's passive loss deductions. |
Beavers, James A. |
|
Mar 1, 2017 |
1816 |
| Tax Court rules in favor of taxpayers in passive activity loss case. |
Brown, Mark |
|
Nov 1, 2016 |
1076 |
| Issues involving the interplay of subpart F income recapture account and sec. 956 inclusion. |
Weeden, Treavor; Yu, Hui |
|
Jul 1, 2016 |
1201 |
| Meeting the 100-hour significant participation activity test. |
Graat, Brenda M.; Malczewski, James J. |
|
Oct 1, 2015 |
1688 |
| Passive activity credit flowchart. |
Koehler, Kevin |
|
Oct 1, 2015 |
1161 |
| Reporting information regarding LLCs' passive activities. |
Ellentuck, Albert B. |
|
Jun 1, 2015 |
1227 |
| CCA affects taxpayer's ability to qualify as a real estate professional. |
Bilsky, Jeffrey N.; Goodman, Avi D. |
|
May 1, 2015 |
1275 |
| Net investment income tax surprise: significant participation rule trumping material participation tests. |
Stamper, Dustin |
|
Feb 1, 2015 |
2134 |
| Interplay of the rental real estate grouping election and real estate professional exception. |
Miles, Adam |
|
Dec 1, 2014 |
1189 |
| Sec. 121 gain exclusion does not offset suspended passive losses: qualifying taxpayers who convert a principal residence to rental property and sell it can exclude gain under Sec. 121 without offsetting any passive losses carried forward. |
Reichert, Charles J. |
|
Oct 1, 2014 |
382 |
| Trust can be a real estate professional: trustees performing services on a trust's behalf qualify the trust for the exception for real estate professionals to the passive activity loss disallowance. |
Reichert, Charles J. |
|
Jul 1, 2014 |
730 |
| Real estate professionals: avoiding the passive activity loss rules. |
SkarbHk, John H. |
|
Jul 1, 2014 |
7167 |
| A 21st century PFIC regime: must all working capital be passive? |
Barner, Brian; Olivas, Julie; Shoff, Camille |
|
May 1, 2014 |
1438 |
| Taxpayer is not a real estate professional. |
Beavers, James A. |
|
May 1, 2014 |
1004 |
| Sorry, you can't get there from here: the untenable goal of using short-term rental real estate to attain real estate professional status. |
Kofsky, Ausher M.B. |
|
Mar 22, 2014 |
13996 |
| New PFIC regulations clarify reporting requirements. |
Caballero, Michael J.; Suringa, Dirk; Yen, Jason |
|
Jan 1, 2014 |
3409 |
| Higher stakes for tax treatment of rental real estate: help clients manage both the new net investment income tax and passive loss limitations. |
Panitz, Philip Garrett; Lubin, Barbara |
|
Dec 1, 2013 |
3852 |
| When is stock worthless? |
McKinley, John W.; Kimmey, Matthew |
|
Nov 1, 2013 |
838 |
| Tiered partnerships: will net investment income tax and proposals to change taxation of carried interests wreak havoc? |
Etienne, Corinne; McCreary, Lee |
|
Aug 1, 2013 |
1800 |
| Cross-border taxation. |
Leibowicz, Barry |
|
Mar 1, 2013 |
5727 |
| Telecommunication tower leases not subject to self-rental passive income rule. |
Meade, Janet A. |
|
Feb 1, 2013 |
723 |
| Grouping passive activities. |
Nevius, Alistair M. |
|
Feb 1, 2013 |
546 |
| Activity grouping: the impact of recent developments. |
Rowe, Daniel |
|
Feb 1, 2013 |
3166 |
| Determining a member's participation in LLC activities. |
Ellentuck, Albert B. |
|
Feb 1, 2013 |
1388 |
| IRS not allowed to reclassify passive activity income. |
Beavers, James A. |
|
Feb 1, 2013 |
1479 |
| What is an item of property? |
Reichert, Charles J. |
|
Nov 1, 2012 |
536 |
| QEF elections under PFIC rules. |
Usher, Scott F.; Pitner, Diana L.; Martin, Bader |
|
Oct 1, 2012 |
980 |
| When becoming a U.S. resident, beware of PFIC rules. |
Whittall, Robert E. |
|
Aug 1, 2012 |
1143 |
| Interaction of the subpart F dual-character property and majority-use rules. |
Smith, Annette B. |
|
Jul 1, 2012 |
1077 |
| Potential pitfalls in PFIC reporting. |
Smith, Annette B. |
|
Jul 1, 2012 |
1155 |
| Who is a limited partner? The IRS issues sec. 469 prop. regs. |
Van Leuven, Mary |
|
Jun 1, 2012 |
1591 |
| Limited partners and material participation: a tax planning opportunity. |
Johnson, Michael |
|
Apr 1, 2012 |
812 |
| LLC member participation rules proposed. |
Bonner, Paul |
|
Mar 1, 2012 |
402 |
| Effective taxation of carried interest: a comprehensive pass-through approach. |
Sacks, Jason A. |
|
Jan 1, 2012 |
15229 |
| Short-term rentals preclude use of losses. |
Pierce, Pamela L. |
|
Nov 1, 2011 |
792 |
| Passive foreign investment companies. |
Wong, Alan |
|
Oct 1, 2011 |
1853 |
| Relief for late election to treat all real estate rental interests as one activity. |
Wong, Alan |
|
Oct 1, 2011 |
1863 |
| Case study: changing level of participation in an S corporation for Tax Planning purposes. |
Ellentuck, Albert B. |
|
Aug 1, 2011 |
1477 |
| Current developments in partners and partnerships. |
Burton, Hughlene A. |
|
Feb 1, 2011 |
7418 |
| Taking the "sting" out of S Corporations' earnings and profits: taxpayers can elect several methods to avoid a sizable tax bite. |
Traum, Sydney S. |
|
Jan 1, 2011 |
2308 |
| Taxpayer off the clock for real estate loss. |
Schnee, Edward J. |
|
Dec 1, 2010 |
689 |
| Planning for the new Medicare taxes. |
Knittel, David |
|
Dec 1, 2010 |
1550 |
| Grouping rental real estate activities under Regs. Secs. 1.469-4 and 1.469-9. |
Janz, Ellen |
|
Dec 1, 2010 |
1760 |
| S Corporations with earnings and profits. |
Traum, Sydney S. |
|
Dec 1, 2010 |
1852 |
| Increasing passive activity loss deductions with self-charged interest. |
Ellentuck, Albert B. |
|
Dec 1, 2010 |
1424 |
| Case study: maximizing the use of the special $25,000 rental real estate loss allowance. |
Ellentuck, Albert B. |
|
Nov 1, 2010 |
901 |
| Recharacterization of income from nonpassive to passive is not a change in accounting method. |
Beavers, James A. |
|
Nov 1, 2010 |
991 |
| Application of sec. 1297(d) overlap rule to PFIC shares held by a U.S. partnership. |
Asher, Nita |
|
Jul 1, 2010 |
1087 |
| Potential implication of recent sec. 469 court decisions for self-employment tax rules. |
Ellis, Audrey; Rosenberg, Jeffrey |
|
Jul 1, 2010 |
1128 |
| Applying the material participation standards to nongrantor trusts. |
Williamson, Donald T.; Staley, A. Blair |
|
Jun 1, 2010 |
5089 |
| Deducting LLC losses. |
Schnee, Edward J. |
|
May 1, 2010 |
628 |
| Revenue procedure adds new disclosure requirements for grouping of passive activities. |
Patch, David |
|
May 1, 2010 |
1063 |
| Passive activity grouping disclosure statements. |
Miller, John L. |
|
Apr 1, 2010 |
801 |
| Real estate professionals: do their rentals qualify for nonpassive status? |
Prentice, Kristin |
|
Dec 1, 2009 |
1449 |
| LLCs, LLPs, and the passive loss rules. |
Calderilla, Cecilia |
|
Nov 1, 2009 |
1249 |
| Losses from interests in LLCs and LLPs not presumptively passive. |
Quinn, Tina; Robertson, John F. |
|
Oct 1, 2009 |
1121 |
| Passive activity rules not presumed to apply to LLCs and LLPs. |
Valdez, Veronica |
|
Oct 1, 2009 |
1217 |
| Interests in LLCs and LLPs not presumed to be passive activities. |
Beavers, James |
|
Sep 1, 2009 |
1671 |
| A broker is what a broker does. |
Reichert, Charles J. |
|
Jun 1, 2009 |
631 |
| Partners' agreement subject to at-risk rules. |
Schnee, Edward J. |
|
Feb 1, 2009 |
692 |
| Proof of material participation must be credible. |
Kreissl, Laura Jean; Pulliam, Darlene |
|
Dec 1, 2008 |
352 |
| Treatment of investment interest expense allocable to partnership's trading activity. |
Oberst, Timothy S. |
|
Oct 1, 2008 |
1617 |
| Avoiding the self-rental trap. |
Constantine, Anthony J. |
|
Aug 1, 2008 |
1619 |
| Converting a residence to rental property. |
Ellentuck, Albert B. |
|
Jul 1, 2008 |
1771 |
| Disposing of an activity to release suspended passive losses. |
Ellentuck, Albert B. |
|
May 1, 2008 |
2125 |
| Passive or nonpassive activity - IRS wins either way. |
Reichert, Charles J. |
|
Feb 1, 2008 |
690 |
| Tax planning for vacation home owners. |
Ellentuck, Albert B. |
|
Jul 1, 2006 |
1116 |
| Equipment leasing losses were not passive. |
Lindbloom, John W. |
|
Oct 1, 2005 |
644 |
| Benefits and drawbacks for rental real estate professionals. |
Matthys, Russ |
|
Sep 1, 2005 |
1723 |
| Extraordinary personal services exception. |
Reichert, Charles J. |
|
Jun 1, 2005 |
667 |
| Partnerships, PFICs and QEFs. |
Cowan, Jeffrey P. |
|
Jun 1, 2005 |
1883 |
| S Corporation passive income. |
Liewen, Laura J. |
|
Dec 1, 2004 |
488 |
| Self-rental rule not affected by grouping activities. |
Carlos, Tony R. |
|
Dec 1, 2004 |
727 |
| Determining deductibility of passive losses. |
Ellentuck, Albert B. |
|
Aug 1, 2004 |
654 |
| PFIC deferred tax amount: timing is everything. |
Cowan, Jeffrey P., Jr. |
|
Jun 1, 2004 |
1924 |
| Defining "real estate professional" for PAL purposes. |
Koppel, Michael D. |
|
Dec 1, 2003 |
556 |
| Avoiding the 25% passive gross receipts problem by using a stock redemption to remove excess investments. |
Ellentuck, Albert B. |
|
Dec 1, 2003 |
1237 |
| Losses trust deducted were not from passive activity. |
Nash, Claire Y. |
|
Nov 1, 2003 |
607 |
| Trust's material participation not limited to trustee's activity. |
O'Driscoll, David |
|
Jul 1, 2003 |
600 |
| Applying the indirect ownership rules to PFICs. |
Madden, David |
|
Jun 1, 2003 |
1976 |
| PFIC/CFC overlap: not out of the woods yet. |
Madden, David |
|
Jun 1, 2003 |
1692 |
| Final passive loss regs issued. (IRS News). |
Josephs, Stuart R. |
Brief Article |
Oct 1, 2002 |
123 |
| Grouping activities as an AEU. |
Miller, Sarah Allen |
|
Sep 1, 2002 |
1622 |
| PFICs: applying the subsidiary look-through rules to intercompany transactions. |
Laudeman, Robert |
|
Jun 1, 2002 |
2009 |
| Mark-to-market election is not a disposition for PAL purposes. |
Fiore, Nicholas J. |
|
Jun 1, 2002 |
323 |
| Self-rental regulation upheld again. |
Reichert, Charles J. |
|
May 1, 2002 |
632 |
| PALs carried forward from C to S Corporation. |
Lerman, Jerry L. |
|
Apr 1, 2002 |
399 |
| Recognizing suspended passive losses when S stock is transferred to a family member. |
Ellentuck, Albert B. |
|
Apr 1, 2002 |
1052 |
| An analysis of the St. Charles decision. (A Victory for the Taxpayer). |
Colburn, Steven C. |
|
Feb 1, 2002 |
3862 |
| S shareholder cannot offset self-charged management fees against nonpassive income. |
Fiore, Nicholas J. |
|
Sep 1, 2001 |
920 |
| S corporation can deduct suspended PALs incurred while a C corporation. |
Bakale, Anthony |
|
Aug 1, 2001 |
1278 |
| Passive losses and LLC Members. |
Schnee, Edward J. |
|
Jul 1, 2001 |
567 |
| Foreign national tax planning to avoid PFIC trap. |
Madden, David |
|
Jun 1, 2001 |
886 |
| LLC member not limited partner sec. 469 purposes. |
Madden, David |
|
Jun 1, 2001 |
1449 |
| Passive loss carryovers - a reversal. |
Schnee, Edward J. |
|
May 1, 2001 |
603 |
| Self-rent and passive losses. |
Schnee, Edward J. |
|
May 1, 2001 |
577 |
| Passive losses and sec. 731 gain. |
Packard, Pamela |
|
May 1, 2001 |
574 |
| Suspended PALs from C years could be deducted in S election year. |
Fiore, Nicholas J. |
|
Jan 1, 2001 |
1311 |
| The anticompetitive effect of passive investment. |
Gilo, David |
|
Oct 1, 2000 |
24106 |
| When is a rental property not a rental property? |
Moore, Philip E. |
|
Oct 1, 2000 |
721 |
| Self-rental income considered "active". |
Lynch, Michael |
|
Sep 1, 2000 |
456 |
| Aggregating your rental activity? Be sure to tell the IRS. |
Lynch, Michael |
|
Jul 1, 2000 |
585 |
| Don't be passive. |
Lynch, Michael |
|
Jun 1, 2000 |
460 |
| Avoiding the PFIC web when liquidating a non-QEF. |
Mach, Joseph |
|
May 1, 2000 |
1483 |
| Avoiding involuntary termination of S status from excess passive investment income. |
Ellentuck, Albert B. |
|
Apr 1, 2000 |
1313 |
| Short-term rentals classified as passive activity losses. |
Lee, Cynthia Bolt |
|
Jan 1, 2000 |
538 |
| Rental income not PII. |
White, George L. |
|
Dec 1, 1999 |
545 |
| Loan proceeds and passive activity losses. |
Ellentuck, Albert B. |
|
Jun 1, 1998 |
1105 |
| Tax planning opportunities for real estate professionals. |
Barats, Yunna |
|
May 1, 1998 |
712 |
| Do basis and risk limitations affect using tips credit? |
Albin, John M. |
|
Aug 1, 1997 |
550 |
| What happened to limited partnerships? |
Knight, Ray |
|
Jul 1, 1997 |
3061 |
| Passthrough investments by exempt organizations. |
Dally, Curtis L. |
|
May 1, 1997 |
532 |
| Avoiding the pitfalls associated with attempts to recharacterize activities. |
Ellentuck, Albert B. |
|
May 1, 1997 |
718 |
| Rental activity as a closely held business. |
Hudson, Boyd D. |
|
Jan 1, 1997 |
575 |
| Tax benefits for partners in "trading" partnerships. |
Torella, Lawrence |
|
Aug 1, 1996 |
819 |
| Use of management company prevents taxpayer from claiming active participation in rental property. |
Bowers, Jennifer J. |
|
Aug 1, 1996 |
585 |
| Passive activity loss rules to remember for decedents & estates. |
Conway, Margaret |
|
Jul 1, 1996 |
1454 |
| Will changes to the passive income rules renew interest in real estate? |
Lipman, Francine J.; Williamson, James E. |
|
May 1, 1996 |
951 |
| UBIT consequences of certain passive income from subsidiaries. |
Mackay, Jim |
Brief Article |
Apr 1, 1996 |
289 |
| Final regulations deem net income from rental to close corporation nonpassive. |
Ochsenschlager, Thomas P. |
Brief Article |
Feb 1, 1996 |
411 |
| Condo owners fail material participation test. |
Lynch, Michael |
Brief Article |
Feb 1, 1996 |
440 |
| New restrictions on passive income generators. |
Dalton, Thomas M.; Luckey, James M. |
|
Jan 1, 1996 |
2080 |
| Repeal of section 956A: excess passive assets. |
|
|
Jan 1, 1996 |
590 |
| Passive loss relief for real estate professionals. |
Corrick, Stephen R. |
|
Nov 1, 1995 |
1314 |
| Convert C corporation to S corporation at retirement for passive income. |
Brown, Robert R. |
|
Aug 1, 1995 |
672 |
| Short-term rental not qualified for APRRE. |
Moavero, James A. |
|
Aug 1, 1995 |
635 |
| The chameleon character of interest expense during the rental of a residence. |
Tripp, John C. |
|
Jul 1, 1995 |
3727 |
| Passive activities and real estate persons: understanding the RRA '93 requirements. |
Dilley, Steven C.; Young, James C. |
|
Jun 1, 1995 |
2290 |
| Minimizing AGI-based deduction limits by shifting family income: big savings possible despite the kiddie tax. |
Gervais, Paul L., Jr. |
|
Jun 1, 1995 |
1989 |
| PAL rules: definition of activity. |
Schmalz, John G. |
|
Apr 1, 1995 |
648 |
| Release of capital and passive losses in dispositions of passive activities. |
Velten, James E. |
Brief Article |
Apr 1, 1995 |
469 |
| Deducting suspended losses on disposition of S stock. |
Ellentuck, Albert B. |
|
Apr 1, 1995 |
750 |
| Minimizing self-employment tax: strategies to reduce the tax burden. |
Cleveland, Grover |
|
Mar 1, 1995 |
5339 |
| Calculating the effects of exempt income on the excess net passive income tax. |
Ellentuck, Albert B. |
|
Dec 1, 1994 |
501 |
| Expiration of the Sec. 469 temporary regulations for C corporations. |
Gratz, Michael |
|
Oct 1, 1994 |
840 |
| Rental real estate and sec. 1375. |
Ruefenacht, Kim |
|
Sep 1, 1994 |
671 |
| Disallowed PALs increase basis when estate distributes the activity. |
Schooley, Rita L. |
Brief Article |
Aug 1, 1994 |
280 |
| The effect of the Revenue Reconciliation Act of 1993 on real estate owners. |
Sage, Lloyd G. |
|
Aug 1, 1994 |
4781 |
| Passive losses get audit guide. |
|
Brief Article |
Jul 1, 1994 |
99 |
| Passive loss included in NOL may be carried back. |
Porter, Jack |
Brief Article |
May 1, 1994 |
420 |
| Passive loss relief for real estate professionals: fact or fiction? |
Gladstone, Debra L. |
|
May 1, 1994 |
1199 |
| Determining the deductibility of S corporation passive losses. |
|
|
May 1, 1994 |
684 |
| Gifts of passive activities may yield a surprising result. |
Svagna, Marco |
|
Mar 1, 1994 |
1002 |
| Planning for distributions of passive activities by estates. |
Svagna, Marco |
|
Mar 1, 1994 |
995 |
| Adverse consequences to U.S. shareholders of PFICs. |
Melcher, Gary |
|
Mar 1, 1994 |
773 |
| Temporarily converting a personal residence to income-producing property. |
Miller, Sandra K. |
|
Feb 1, 1994 |
2846 |
| Carryover of passive losses and other tax attributes to an individual bankruptcy estate. |
Knickel, David W. |
|
Nov 1, 1993 |
1439 |
| S corporation planning after discontinuing active trades or businesses (or penalty taxes to be wary of). |
Stone, Howard A. |
|
Oct 1, 1993 |
1402 |
| Passive foreign investment companies. |
Fox, Stephen C. |
|
May 1, 1993 |
1564 |
| Individual bankruptcy regulations provide guidance. |
Rosenberg, Neil |
|
Apr 1, 1993 |
765 |
| Proposed passive foreign investment company regulations. |
|
|
Mar 1, 1993 |
2797 |
| Bankruptcy estate can't use bankrupt's passive losses. |
|
Brief Article |
Mar 1, 1993 |
242 |
| S corporations: new opportunities for rental activities? |
|
Brief Article |
Mar 1, 1993 |
302 |
| The new passive activity regulations: simplification at last? |
Dietrich, Mark O. |
|
Feb 1, 1993 |
3244 |
| Passive-loss bill vetoed, but there's still hope. |
Fitzgerald, Therese |
|
Nov 18, 1992 |
619 |
| New, improved definition of activity. |
Simmons, Kathy |
|
Nov 1, 1992 |
1158 |
| PIGs for your PALs. |
Harrison, James Edward |
|
Sep 1, 1992 |
537 |
| Defining "activity" for passive losses. |
|
Brief Article |
Aug 1, 1992 |
311 |
| Passive income recharacterization in related-party leases. |
Donovan, James J., III |
|
Aug 1, 1992 |
483 |
| PFICs: some new twists to old rules. |
Henderson, Michael E. |
|
Jun 1, 1992 |
762 |
| Passive activity loss allocations; careful planning can reduce the adverse impact of Sec. 469. |
Allen, Stephen D. |
|
May 1, 1992 |
6424 |
| Sec. 58(c)(1) creates potential future AMT from PAL carryforwards. |
Beverly, Marilue |
|
Mar 1, 1992 |
938 |
| Reconsidering the election to segregate rental real estate undertakings. |
Touger, Steven I. |
|
Feb 1, 1992 |
252 |
| Rental of residences. |
Fiore, Nicholas J. |
|
Sep 1, 1990 |
739 |
| Comments on miscellaneous revenue issues considered at February 21-22, 1990, hearings, March 9, 1990. |
Burk, William M. |
|
Mar 1, 1990 |
2425 |
| Working with the passive activity rules. |
Martin, M. Jill Lockwood |
|
Jan 1, 1990 |
4146 |
