CPE Course Section 199/A & Rental Real Estate
June 9, 2020
8:30am — 4:15pm
Topics include a detailed discussion of whether residential rental property (rented pursuant to a gross lease) such as a single family home and non-residential real property (rented pursuant to a triple net lease) rise to the level of a section 162 trade or business for purposes ofSection 199A, the preamble/-1(b)(13) of the proposed regulations and/or the preamble/-1(b)(14) of the final regulations, and the case law such as Higgins, Groetzinger, Fackler, Hazard, Grier, Lagreide, Gilford, The Union National Bank of Troy, and Curphey; the treatment of self-rented property rented to a commonly controlled S corporation or C corporation business; the rental of property to a 50% or more commonly owned SSTB; the possibility of aggregating residential rental property and aggregating non-residential rental property, and the prohibition against aggregating both types of property together; the use of Form 8275 to discloseuncertain tax positions for which there isa reasonable basis; and much more.
Boston Tax Institute