News & Analysis as of

Passive Losses

Taxpayer Victory Helps Trusts Holding Business and Real Estate Avoid Tax

by McDermott Will & Emery on

One of the most vexing tax issues remaining unresolved since the 1986 enactment of the passive loss (PAL) rules is whether business or rental income earned by a trust can be active income and whether business or rental losses...more

IRS Limits Losses Sustained by Trusts

by Baker Donelson on

Since 1986, Section 469 of the Internal Revenue Code has imposed limitations on the ability of most taxpayers to offset losses from activities in which they do not materially participate against wages and other non-passive...more

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