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Some Planning Considerations In Light Of The Second Set Of Pal Regulations, Hans-Dieter Sprohge

Akron Tax Journal

This article consists of three parts: (1) an overview of the definition of an activity, (2) planning considerations, and (3) a summary of amendments to the first set of PAL Regulations. First, the overview section explains that a separate activity is an undertaking that consists of income-producing operations at a single location that are either predominantly rental operations or predominantly trade or business operations. Second, the overview discusses the aggregation and fragmentation rules for rental activities and trade or business activities. The Regulations provide detailed rules only for aggregating separate rental real estate activities into a single activity or for …