by Aninda DharEarlier this year, the IRS released Revenue Procedure 2010-13 which requires taxpayers to report activities for the purposes of the passive activity loss (PAL) rules designated by IRC Section 469 and Reg. Section 1.469-4. As part of their annual tax return, taxpayers must formally disclose in writing, new groupings and regroupings, and the addition and subtraction of specific activities within existent groupings. Pre-existing groupings need not be disclosed unless a change has been made because the initial grouping was "clearly inappropriate" or due to a change in underlying material facts and circumstances.
The new rules are effective for tax years beginning on or after January 25, 2010.
If you have any comments or questions regarding this post, please contact Ken Weissenberg or Aninda Dhar.
