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Passive Activity Loss Rules: Strategies for Pass‐Throughs to Maximize DeductionsLeveraging Latest Federal Guidance and Rulings to Establish Material Participation

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TUESDAY, FEBRUARY 28, 2012

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1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific

Anne Bushman, Tax Services Manager, McGladrey & Pullen, Washington, D.C., g , y , g ,

Peter Jorstad, Tax Manager, CJBS, Northbrook

Michael Grace, Managing Director, Milbank Tweed Hadley & McCloy, Washington, D.C.

Monica Tillett, Managing Director, WTAS LLC, Washington, D.C.

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Form 8582 Department of the Treasury Internal Revenue Service (99)

Passive Activity Loss Limitations See separate instructions.

Attach to Form 1040 or Form 1041.

OMB No. 1545-1008

2011Attachment Sequence No. 88

Name(s) shown on return Identifying number

Part I 2011 Passive Activity Loss

Caution: Complete Worksheets 1, 2, and 3 before completing Part I.

Rental Real Estate Activities With Active Participation (For the definition of active participation, see Special Allowance for Rental Real Estate Activities in the instructions.)

1

a

Activities with net income (enter the amount from Worksheet 1, column (a)) . . . . . . . . . . . . . . . . . . 1a

b

Activities with net loss (enter the amount from Worksheet 1, column(b)) . . . . . . . . . . . . . . . . . . . . . 1b ( )

c

Prior years unallowed losses (enter the amount from Worksheet 1, column (c)) . . . . . . . . . . . . . . . . . . 1c ( )

d Combine lines 1a, 1b, and 1c . . . . . . . . . . . . . . . . . . . . . . 1d

Commercial Revitalization Deductions From Rental Real Estate Activities

2 a Commercial revitalization deductions from Worksheet 2, column (a) . 2a ( )

b

Prior year unallowed commercial revitalization deductions from Worksheet 2, column (b) . . . . . . . . . . . . . . 2b ( )

c Add lines 2a and 2b . . . . . . . . . . . . . . . . . . . . . . . . . 2c ( )All Other Passive Activities

3

a

Activities with net income (enter the amount from Worksheet 3, column (a)) . . . . . . . . . . . . . . . . . . 3a

b

Activities with net loss (enter the amount from Worksheet 3, column(b)) . . . . . . . . . . . . . . . . . . . . . 3b ( )

c

Prior years unallowed losses (enter the amount from Worksheet 3, column (c)) . . . . . . . . . . . . . . . . . . 3c ( )

d Combine lines 3a, 3b, and 3c . . . . . . . . . . . . . . . . . . . . . . 3d

4

Combine lines 1d, 2c, and 3d. If this line is zero or more, stop here and include this form withyour return; all losses are allowed, including any prior year unallowed losses entered on line 1c, 2b, or 3c. Report the losses on the forms and schedules normally used . . . . . . . . 4

If line 4 is a loss and: • Line 1d is a loss, go to Part II. • Line 2c is a loss (and line 1d is zero or more), skip Part II and go to Part III. • Line 3d is a loss (and lines 1d and 2c are zero or more), skip Parts II and III and go to line 15.

Caution: If your filing status is married filing separately and you lived with your spouse at any time during the year, do not complete Part II or Part III. Instead, go to line 15.Part II Special Allowance for Rental Real Estate Activities With Active Participation

Note: Enter all numbers in Part II as positive amounts. See instructions for an example.5 Enter the smaller of the loss on line 1d or the loss on line 4 . . . . . . . . . . . . 5

6 Enter $150,000. If married filing separately, see instructions . . 6

7 Enter modified adjusted gross income, but not less than zero (see instructions) 7

Note: If line 7 is greater than or equal to line 6, skip lines 8 and 9, enter -0- on line 10. Otherwise, go to line 8.

8 Subtract line 7 from line 6 . . . . . . . . . . . . . 8

9 Multiply line 8 by 50% (.5). Do not enter more than $25,000. If married filing separately, see instructions 9

10 Enter the smaller of line 5 or line 9 . . . . . . . . . . . . . . . . . . . . 10

If line 2c is a loss, go to Part III. Otherwise, go to line 15.Part III Special Allowance for Commercial Revitalization Deductions From Rental Real Estate Activities

Note: Enter all numbers in Part III as positive amounts. See the example for Part II in the instructions.11 Enter $25,000 reduced by the amount, if any, on line 10. If married filing separately, see instructions 11

12 Enter the loss from line 4 . . . . . . . . . . . . . . . . . . . . . . . . 12

13 Reduce line 12 by the amount on line 10 . . . . . . . . . . . . . . . . . . 13

14 Enter the smallest of line 2c (treated as a positive amount), line 11, or line 13 . . . . . . 14

Part IV Total Losses Allowed

15 Add the income, if any, on lines 1a and 3a and enter the total . . . . . . . . . . . . 15

16

Total losses allowed from all passive activities for 2011. Add lines 10, 14, and 15. See

instructions to find out how to report the losses on your tax return . . . . . . . . . . . 16

For Paperwork Reduction Act Notice, see instructions. Cat. No. 63704F Form 8582 (2011)

Form 8582 (2011) Page 2

Caution: The worksheets must be filed with your tax return. Keep a copy for your records.Worksheet 1—For Form 8582, Lines 1a, 1b, and 1c (See instructions.)

Name of activity

Current year Prior years Overall gain or loss

(a) Net income

(line 1a)(b) Net loss

(line 1b)(c) Unallowed loss (line 1c)

(d) Gain (e) Loss

Total. Enter on Form 8582, lines 1a, 1b,

and 1c . . . . . . . . . . .Worksheet 2—For Form 8582, Lines 2a and 2b (See instructions.)

Name of activity(a) Current year

deductions (line 2a)(b) Prior year

unallowed deductions (line 2b)(c) Overall loss

Total. Enter on Form 8582, lines 2a and

2b . . . . . . . . . . . .Worksheet 3—For Form 8582, Lines 3a, 3b, and 3c (See instructions.)

Name of activity

Current year Prior years Overall gain or loss

(a) Net income

(line 3a)(b) Net loss

(line 3b)(c) Unallowed loss (line 3c)

(d) Gain (e) Loss

Total. Enter on Form 8582, lines 3a, 3b,

and 3c . . . . . . . . . . .Worksheet 4—Use this worksheet if an amount is shown on Form 8582, line 10 or 14 (See instructions.)

Name of activity

Form or schedule and line number

to be reported on (see instructions)

(a) Loss (b) Ratio(c) Special allowance

(d) Subtract column (c) from

column (a)

Total . . . . . . . . . . . . . . . . . Worksheet 5—Allocation of Unallowed Losses (See instructions.)

Name of activity


to be reported on (see instructions)

(a) Loss (b) Ratio (c) Unallowed loss

Total . . . . . . . . . . . . . . . . . . . Form 8582 (2011)

1.00

1.00

Form 8582 (2011) Page 3

Worksheet 6—Allowed Losses (See instructions.)

Name of activity

Form or schedule and line number to be reported on (see

instructions)

(a) Loss (b) Unallowed loss (c) Allowed loss

Total . . . . . . . . . . . . . . . . . . . Worksheet 7—Activities With Losses Reported on Two or More Forms or Schedules (See instructions.)Name of activity:

(a) (b) (c) Ratio(d) Unallowed

loss(e) Allowed loss


to be reported on (see

instructions):

1a

Net loss plus prior year unallowed loss from form or schedule .

b

Net income from form or schedule . . . . . . .

c Subtract line 1b from line 1a. If zero or less, enter -0-



instructions):

1a


b





instructions):

1a


b



Total . . . . . . . . . . . . . . . . . .Form 8582 (2011)

1.00

1

Part III Administrative, Procedural, and Miscellaneous 26 CFR 469, 1.469-9(g): Rules for certain rental real estate activities (Also: Part 1, §§ 301.9100-1, 301.9100-3) Rev. Proc. 2011-34 SECTION 1. PURPOSE

This revenue procedure provides guidance under § 1.469-9(g) of the Income Tax Regulations allowing certain taxpayers to make late elections to treat all interests in rental real estate as a single rental real estate activity.

SECTION 2. BACKGROUND

.01 Section 469 of the Internal Revenue Code generally imposes restrictions on the allowance of passive activity losses and credits in the case of individuals and certain other taxpayers.

.02 Under § 469(c)(2), the term "passive activity" generally includes any rental

activity. Section 469(c)(7) provides a limited exception to this rule for taxpayers in a real property business. Specifically, § 469(c)(7)(A) provides that if a taxpayer meets the requirements of § 469(c)(7)(B), the taxpayer's rental real estate activity will no longer be presumptively passive. In general, § 469(c)(7)(A) provides that a taxpayer’s interests in rental real estate are treated as separate activities for determining whether the taxpayer materially participates in each rental real estate activity unless the taxpayer elects to treat all of the taxpayer’s interests in rental real estate as a single rental real estate activity. .03 Section 1.469-9(g)(1) provides that a qualifying taxpayer may make an election to treat all of the taxpayer’s interests in rental real estate as a single rental real estate activity.

.04 Section 1.469-9(g)(3) provides that a qualifying taxpayer makes the election

2

to treat all interests in rental real estate as a single rental real estate activity by filing a statement with the taxpayer's original income tax return for the taxable year. Section 1.469-9(g)(3) describes the information that must be contained in the statement.

.05 Under § 301.9100-1(c), the Commissioner may grant a reasonable extension of time to make a regulatory election, or a statutory election (but no more than six months except in the case of a taxpayer who is abroad), under all subtitles of the Code, except subtitles E, G, H, and I. Section 301.9100-1(b) defines the term "regulatory election" as including an election whose deadline is prescribed by a regulation published in the Internal Revenue Bulletin. .06 Sections 301.9100-1 through 301.9100-3 provide the standards that the Commissioner will use to determine whether to grant an extension of time to make an election. .07 Section 301.9100-2 provides automatic extensions of time for making certain elections. Section 301.9100-3 provides extensions of time for making elections that do not meet the requirements of § 301.9100-2. .08 Section 301.9100-3(a) provides that requests for relief under § 301.9100-3 will be granted when the taxpayer provides evidence to establish that the taxpayer acted reasonably and in good faith, and the grant of relief will not prejudice the interests of the government. .09 Section 301.9100-3(b)(1) provides that subject to paragraphs (b)(3)(i) through (iii) of § 301.9100-3, a taxpayer is deemed to have acted reasonably and in good faith if the taxpayer meets one of the requirements in § 301.9100-3(b)(1)(i)-(v), which include that the taxpayer reasonably relied on a qualified tax professional, including a tax professional employed by the taxpayer, and the tax professional failed to make, or advise the taxpayer to make the election. SECTION 3. SCOPE

.01 This revenue procedure provides special procedures for relief for late § 1.469-9(g) elections.

.02 The procedures in this revenue procedure are in lieu of the letter ruling

procedure that is used to obtain relief for a late § 1.469-9(g) election. Accordingly, user fees do not apply to corrective action under this revenue procedure.

.03 A taxpayer that is not eligible for relief under this revenue procedure may

request relief by applying for a private letter ruling. The Service will not ordinarily issue a private letter ruling under § 1.469-9(g) if the period of limitations on assessment under

3

§ 6501(a) has lapsed for any taxable year that would be affected by the requested late election. Rev. Proc. 2011-1, 2011-1 I.R.B. 1 (or its successor) prescribes the procedural requirements for requesting a private letter ruling.

SECTION 4. APPLICATION .01 Eligibility for relief. A taxpayer is eligible for an extension of time to file a § 1.469-9(g) election under Section 4.03 of this revenue procedure if the taxpayer represents on a statement that satisfies the procedural requirements of section 4.02 of this section and under penalties of perjury that it meets all of the following requirements:

(1) the taxpayer failed to make an election under § 1.469-9(g) solely because the taxpayer failed to timely meet the requirements in §1.469-9(g);

(2) the taxpayer filed consistently with having made an election under § 1.469-9(g) on any return that would have been affected if the taxpayer had timely made the election. The taxpayer must have filed all required federal income tax returns consistent with the requested aggregation for all of the years including and following the year the taxpayer intends the requested aggregation to be effective and no tax returns containing positions inconsistent with the requested aggregation may have been filed by or with respect to the taxpayer during any of the taxable years;

(3) the taxpayer timely filed each return that would have been affected by the election if it had been timely made. The taxpayer will be treated as having timely filed a required tax or information return if the return is filed within 6 months after its due date, excluding extensions;

(4) the taxpayer has reasonable cause for its failure to meet the requirements in § 1.469-9(g).

.02 Procedural requirements for requesting relief. The taxpayer must attach the

statement required by § 1.469-9(g)(3) to an amended return for the most recent tax year and mail the amended return to the IRS service center where the taxpayer will file its current year tax return. The statement must contain the declaration required by § 1.469-9(g)(3), must explain the reason for the failure to file a timely election, and must include the representations required in section 4.01 of this revenue procedure. The statement must identify the taxable year for which it seeks to make the late election. Finally, the statement must state at the top of the document “FILED PURSUANT TO REV. PROC. 2011-34.”

The declaration and representations required in sections 4.01 and 4.02 of this

revenue procedure must be accompanied by a dated declaration, signed by the taxpayer which states: “Under penalties of perjury I (we) declare that I (we) have examined this election, including any accompanying documents, and, to the best of my (our) knowledge and belief, the election contains all the relevant facts relating to the

4

election, and such facts are true, correct, and complete.” The individual or individuals who sign must have personal knowledge of the facts and circumstances related to the election.

.03 Relief for late election under § 1.469-9(g). The Service will notify the taxpayer

upon receipt of a completed application requesting relief under this revenue procedure that satisfies the procedural requirements under section 4.02 of this revenue procedure. Any taxpayer receiving relief under this revenue procedure is treated as having made a timely election to treat all interests in rental real estate as a single rental real estate activity as of the taxable year for which the late election was requested.

SECTION 5. AREAS NOT COVERED BY THIS REVENUE PROCEDURE

The granting of an extension of time to file an election under § 1.469-9(g) pursuant to this revenue procedure and the issuance of a notification described in section 4.03 do not constitute an express or implied determination concerning whether the taxpayer satisfies the eligibility requirements under section 4.01 of this revenue procedure, whether the taxpayer satisfies the requirements under § 469(c)(7)(B), or whether the taxpayer materially participates in any activity. SECTION 6. EFFECTIVE DATE

This revenue procedure is effective on the date of publication of this revenue procedure in the Internal Revenue Bulletin. This revenue procedure also applies to all ruling requests pending in the national office on June 13, 2011, and to requests for relief received thereafter. The national office will decline to rule on all ruling requests currently pending as of June 13, 2011, and will refund the user fee.

SECTION 7. PAPERWORK REDUCTION ACT

The collections of information contained in this revenue procedure have been

reviewed and approved by the Office of Management and Budget (OMB) in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)) under control number 1545-2194.

The collection of information in this revenue procedure is in Section 4.02 of this

revenue procedure. The information will help the IRS to determine whether a taxpayer has met the requirements of Section 4 of this revenue procedure and whether a taxpayer has reasonable cause for failing to make a timely election. The collection of information is required to make a late election pursuant to this revenue procedure. The information will be reported on a statement filed by the taxpayer with the applicable IRS Service Center. The time needed to complete and file the statement will vary depending on individual circumstances. The estimated burden for taxpayers filing the statement is

5

included in the estimates shown in the Paperwork Reduction Act of the annually published letter ruling revenue procedure.

The estimated total annual reporting burden for the taxable years in which this

revenue procedure applies is 1,000 hours. The estimated annual burden per respondent for the taxable years in which this

revenue procedure applies varies from 15 minutes to 45 minutes, depending on individual circumstances, with an estimated average burden of 30 minutes. The estimated annual number of respondents for the taxable years in which this revenue procedure applies is 2000.

An agency may not conduct or sponsor, and a person is not required to respond

to, a collection of information unless the collection of information displays a valid control number.

Books or records relating to a collection of information must be retained as long

as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103. SECTION 8. DRAFTING INFORMATION

The principal authors of this revenue procedure are Michala P. Irons and Bryan A. Rimmke of the Office of Associate Chief Counsel (Passthroughs & Special Industries). For further information regarding this revenue procedure contact Ms. Irons or Mr. Rimmke on (202) 622-3050 (not a toll free call).

U.S. Income Portfolios: Real Estate Portfolio 549-2nd: Passive Loss Rules Working Papers

Worksheet 9 Sample Election Out of the Self-Charged Interest Rules Under Regs. §1.469-7(g)

Editor's Note: In the case of a taxpayer that receives interest income on debt of a passthrough entity in which the taxpayer owns an interest, Regs. §1.469-7 provides that the interest income the taxpayer receives on the loan, which would normally be characterized as portfolio income, is treated as passive income. This recharacterized income may then be used to offset the passive interest expenses passed through to the taxpayer for the same tax year.

A passthrough entity may elect out of these “self-charged interest” rules by attaching a written statement to the passthrough entity's return (or amended return) that includes the passthrough entity's name, address, and taxpayer identification number, and a declaration that an election is being made under Regs. §1.469-7(g). This election is applicable to all lending transactions between the entity and its owners and is effective for the year made and for all subsequent years that end before the date on which the election is revoked. The election can be revoked only with the consent of the IRS.

Election Out of the Self-Charged Interest Rules Acme Building Rentals LLC

828 Main Street

Anytown, Anystate 12345

EIN: 13-4949574

Attachment to Return for Calendar Year 20__

Pursuant to Regs. §1.469-7(g), the taxpayer hereby elects out of the self-charged interest rules of Regs. §1.469-7(c) and (d).

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U.S. Income Portfolios: Real Estate Portfolio 549-2nd: Passive Loss Rules Working Papers

Worksheet 10 Sample Election Under §469(c)(7) to Aggregate Rental Real Estate Interests

Editor's Note: Under §469(c)(7), individual taxpayers and closely held C corporations that qualify as real estate operators must treat their rental activities as nonpassive upon a showing of material participation. Individual taxpayers will qualify under §469(c)(7) if they meet two eligibility requirements. First, of the personal services that the taxpayer performs in trades or businesses during the taxable year, more than half must be performed in real property trades or businesses (i.e., real property development, redevelopment, construction, reconstruction, acquisition, conversion, rental, operation, management, leasing, or brokerage trades or businesses) in which the taxpayer materially participates. Second, during the taxable year the taxpayer must perform more than 750 hours of services in real property trades or businesses in which he materially participates. For closely held C corporations, the only requirement for qualification during a taxable year is that more than 50% of the corporation's gross receipts for the year must be derived from real property trades or businesses in which the C corporation materially participates. “Gross receipts,” for this purpose, do not include items of portfolio income within the meaning of Regs. §1.469-2T(c)(3). See Regs. §1.469-9(c)(2).

A taxpayer that qualifies under §469(c)(7) may elect to treat all of the taxpayer's interests in rental real estate as a single rental real estate activity. Under Regs. §1.469-9(g)(1), this election is binding for the taxable year in which it is made and for all future years in which the taxpayer is a qualifying taxpayer (even if there are intervening years in which the taxpayer is not a qualifying taxpayer). The election may be made in any year in which the taxpayer is a qualifying taxpayer, and the failure to make the election in one year does not preclude the taxpayer from making the election in a subsequent year. In years in which the taxpayer is not a qualifying taxpayer, the election will not have effect and the taxpayer's activities will be those determined under Regs. §1.469-4. If there is a material change in the taxpayer's facts and circumstances, the taxpayer may revoke the election using the procedure described in the Regs. §1.469-9(g)(3).

Under Regs. §1.469-9(g)(3), a qualifying taxpayer makes the election to treat all interests in rental real estate as a single rental real estate activity by filing a statement with the taxpayer's original income tax return for the taxable year. This statement must contain a declaration that the taxpayer is a qualifying taxpayer for the taxable year and is making the election pursuant to §469(c)(7)(A).

In general, the election under § 469(c)(7) must be made on an original return. However, taxpayers may request relief to make a late election by filing an amended return for their most recent tax year. See Relief for Late Election under §469(c)(7) to Aggregate Rental Real Estate Interests, below.

A taxpayer may revoke the election only in the taxable year in which a material change in the taxpayer's facts and circumstances occurs or in a subsequent year in which the facts and circumstances remain materially changed from those in the taxable year for which the election was made. To revoke the election, the taxpayer must file a statement with the taxpayer's original income tax return for the year of revocation. This statement must contain a declaration that the taxpayer is revoking the election under §469(c)(7)(A) and an explanation of the nature of the material change.

Election Under §469(c)(7) to Aggregate Rental Real Estate Interests Gertrude Johnson

828 Main Street




TIN: 123–45–6789

Attachment to Return for Year 20__

Pursuant to §469(c)(7), the above-named taxpayer, a qualifying taxpayer under §469(c)(7)(B) for the year 20__, hereby elects to treat all of her interests in rental real estate as a single rental real estate activity.

Relief for Late Election under §469(c)(7) to Aggregate Rental Real Estate Interests In general, the election under § 469(c)(7) must be made on an original return. However, taxpayers may request relief to make a late election by filing an amended return for their most recent tax year. Under Rev. Proc. 2011-34, 2011-24 I.R.B. _ (6/13/2011), a taxpayer requesting relief to make a late aggregation election must attach the statement required by Regs. §1.469-9(g)(3) to the amended return. Additionally, the statement must also represent that the taxpayer has filed all required returns consistent with the requested aggregation for all relevant taxable years and the statement must also set forth reasonable cause for the taxpayer's failure to file a timely election. The amended return and the attached statement must be mailed to the IRS service center where the taxpayer will file its current year tax return.

FILED PURSUANT TO REV. PROC. 2011-34

Attachment to Amended Return for Year 20__

Gertrude Johnson

828 Main Street


TIN: 123–45–6789

Attachment to Amended Return for Year 20__

Pursuant to Rev. Proc. 2011-34, the above-named taxpayer, a qualifying taxpayer under § 469(c)(7)(B) for the year 20__, hereby requests relief to make a late election under §469(c)(7), to treat all of her interests in rental real estate as a single rental real estate activity for the 20__ taxable year.

Editor's Note: The statement must identify the taxable year for which the taxpayer seeks to make the late election.

Pursuant to §469(c)(7), the above-named taxpayer, a qualifying taxpayer under §469(c)(7)(B) for the year 20__, hereby elects to treat all of her interests in rental real estate as a single rental real estate activity.

The above-named taxpayer failed to make an election under §1.469-9(g) solely because taxpayer failed to timely meet the requirements in §1.469-9(g).

Editor's Note: The statement must explain the taxpayer's reason for the failure to file a timely election.

The above-named taxpayer has filed consistently with having made an election under §1.469-9(g) on any return that would have been affected if taxpayer had timely made the election.

Editor's Note: The taxpayer must have filed all required federal income tax returns consistent with the requested aggregation for all of the years including and following the year the taxpayer intends the requested aggregation to be effective and no tax returns containing positions inconsistent with the requested aggregation may have been filed by or with respect to the taxpayer during any of the taxable years.

The above-named taxpayer timely filed each return that would have been affected by the election if it had been timely made.

Editor's Note: The taxpayer will be treated as having timely filed a required tax or information return if the return is filed within 6 months after its due date, excluding extensions.



The above-named taxpayer has reasonable cause for its failure to meet the requirements in §1.469-9(g).

Editor's Note: The statement must explain the taxpayer's reason for the failure to file a timely election and must set forth reasonable cause for the taxpayer's failure to file a timely election.

Under penalties of perjury I (we) declare that I (we) have examined this election, including any accompanying documents, and, to the best of my (our) knowledge and belief, the election contains all the relevant facts relating to the election, and such facts are true, correct, and complete.

Editor's Note: The statement must be dated and the individual or individuals who sign the statement must have personal knowledge of the facts and circumstances related to the election.

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