Is there any further guidance, other than vague explanation contained within the draft version of Pub 535, as to what constitutes a rental as being an active trade or business and thus eligible for the 199A deduction? How are other firms handling this? If it’s deemed a trade or business, does that mean we go back to the old rules of being required to issue form 1099-Misc for services provided to the property (gardener, painter, etc.), also?? May be too late to get that info. from the recipient(s)!