rental real estate enterprise grouping for safe harbor - Spidell

rental real estate enterprise grouping for safe harbor

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Message Board rental real estate enterprise grouping for safe harbor

This topic contains 2 replies, has 2 voices, and was last updated by Brent Meyer 2 months, 3 weeks ago.

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  • #164780
    Brent Meyer
    Participant

    Can an individual group rental real estate activities that are passing through from multiple partnerships? And if some partnerships have multiple activities, can each be grouped at the individual level?

    Facts:

    Managing partner and property manager of multiple (8) separate partnerships some of which hold multiple properties. Partner also holds interests in three TICs reported directly on schedule E. If grouped, the 250 hour rule is met. (This is assuming separate books and records can be maintained for each rental real estate enterprise.)

    Some of the partnerships, even if grouped at partnership level, would not qualify for 250 hours but if individual can group, they would.

  • #164797
    William Dewberry
    Participant

    This is not a direct answer to your question, last week i listened to a 2 hour webinar on 199A put on by the IRS; it was actually quite good, and one comment they made was this 250 hour test is being way over analyzed and people thinking its an all or none based on the 250 which has many limitations in application; they suggested taking the easier route and just looking at 162.

  • #164809
    Brent Meyer
    Participant

    Thank you. I have taken that position with some clients but was curious about the RPE issue.