When Does a Trustee’s Activities
Rise to the Level of “Material Participation”?
(So a Trust’s Business or Rental Losses
Can Avoid the Passive Loss Limitation and
Income Can Avoid the 3.8% Net Investment Income Tax?)
If you’re an attorney advising trustees or a CPA preparing trust tax returns, you now have new guidance - - and powerful planning opportunities - - thanks to the recently released U.S. Tax Court case of Frank Aragona Trust v Commissioner.
You need to know how the landscape for the material participation standard of trusts has changed after the Frank Aragona Trust, including the following:
- How IRC Section 469 and the Regulations thereunder now apply to trusts
- How Section 1411 (NIIT) and the Regulations thereunder now apply to trusts
- A fresh understanding of the Congressional Committee Reports and the legislative history of the material participation standard for trusts
- The combined impact of the applicable case law (including Mattie K. Carter and Frank Aragona Trust) and available IRS guidance (including TAM 200733023, LTR 201029014 & LTR 201317010)
- What are the new, possible planning opportunities
Join us and national renowned CPA and tax expert, Robert Keebler, for a very timely 90-minute program entitled, “Trustee Material Participation After the Frank Aragona Trust Decision”.