Passive Activity Loss Rules - The Pendulum, At Long Last, Is Swinging Back Our Direction

Practitioners are increasingly reporting a surge in IRS audit activity enforcing the passive activity loss rules. The pendulum of passive loss cases in the Tax Court, after decades, is swinging more favorably for the taxpayer. How to make sense of it all? This course enables the participant to compentently approach passive activity loss terrain to prevent trouble and create intended results.

**This course is approved by the IRS. The submission of a completed request form, found under the materials tab, is required for credit. Please send completed form to leighanne.conroy@acpen.com.


*To gain a working knowledge of and planning flair for the intricate passive activity loss rules for business and rentals

*To learn the 5 step approach to framing any passive loss analysis, keeping good passive loss files (and records) and preventing tax losses from being temporarily or permanently


*Structuring and operating to avoid losses irretrievably being stranded as “passive”?

*Passive Activity Loss 5 Step Approach – How it saves souls from drowning in the abyss

*What may and may not be grouped together – How grouping can win the battle or sink you

*Fresh Start Regrouping Rules - The biggest thing to hit PAL rules since 1986?

*Why “non-passive” and “active” are not even close to the same thing

*How the way a pass-through entity reports activities can protect or impale you

*How the Tax Court is rewriting the material participation time log (or not) rules

*IRS’ Passive Activity Audit Guide: Biases revealed and secrets told

*Which hurdle do you jump over first? Basis, at-risk, PAL, NOL? Which second, third, fourth?

*How to keep (and show your client how to keep) "off tax return" records to avoid disastrous passive activity train wrecks

*Real estate professional – The “live for today” election – Every hand’s a winner, every hand’s a loser

*Recharacterization rules: Navigating through the land mines to safety

*Effects of various transactions between a closely held entity and its owner, including self charged interest, self charged rent and other self charged transactions

*What do the passive loss rules have to do with estate planning anyway?

*Timing, timing, timing and other freight train stories – a/k/a Why I want a “complete disposition” when I grow up

Additional Information

Designed For

Anyone desiring to gain an in-depth working knowledge of the passive activity loss (PAL) rules and how to avoid losses from being stranded as passive



Advanced Preparation




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