Total Credits: 3 including 3 Taxes
When Congress enacted the Omnibus Budget Reconciliation Act of 1993 it imposed incremental intra-period predicate factual requirements on the inter-period rental real property trade or business activity conclusive presumption. In that legislation, however, Congress did not impose incremental predicate factual requirements on the strictly intra-period Section 469(h)(1) participation conclusive presumption. Since the 1993 legislation, it appears the IRS, the Secretary of the Treasury, taxpayers, and professionals alike continue to confuse whether Congress’s 1993 action imposing the incremental Section 469(c)(7)(B)(i) and (ii) intra-period predicate factual requirements qualified the activity or participation conclusive presumption, or both. This webcast resolves that confusion.
The Activity Conclusive Presumption
The Participation Conclusive Presumption
Noncorporate Lessor Activity Conclusive Presumptions
Section 469(c)(7)(B)’s Rental Real Property Trade or Business Activity Qualifying Predicate Factual Requirements
**Please Note: If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to firstname.lastname@example.org.
|Jenkins_Credentials (0.09 MB)||5 Pages||Available after Purchase|
|Section 469’s Activity_Article (1.54 MB)||Available after Purchase|
|Section 469’s Activity_IRS CE Credit Request form (0.16 MB)||Available after Purchase|
|Section 469 Webcast_FinalSlides (3.24 MB)||122 Pages||Available after Purchase|
|Important CPE Credit Information_READ BEFORE WEBCAST UPDATED (0.47 MB)||Available after Purchase|
David Randall Jenkins, Ph.D., received his doctorate in accounting and a master’s in accounting with an emphasis in tax from the University of Arizona. He has taught financial, managerial, and tax accounting courses at both the graduate and undergraduate levels. Dr. Jenkins is an AACSB academically qualified business school and tax professor owing to his peer reviewed journal article publications. His company, Algorithm LLC (algorithm-llc.com), is an IRS Approved Continuing Education Provider. Dr. Jenkins may be contacted at email@example.com.
Wed, Dec 13, 2017 - 09:00a to 12:00p EST
Tue, Dec 26, 2017 - 08:00p to 11:00p EST
This webcast is an intermediate continuing education webcast.
It is assumed the webcast participant has fundamental knowledge of tax issues, material participation definitions, passive activity losses, section 469(c)(7) rental real estate trade of business activity issues, noncorportate lessor secton 179 100% depreciation expense issues.
*Enrolled Retirement Plan Agents
*Self-directed Retirement Plan Fiduciaries, Custodians, and Administrators
*Self-directed Retirement Plan Account Holders
*Tax Return Preparers
*Recognize how to correctly distinguish conclusive presumption ultimate facts from conclusive presumption predicate facts
*Recognize that trade or business activity conclusive presumptions are correctly considered inter-period because both historic and prospective facts and factors are taken into account in making such activity determinations in each and every taxable period
*Recognize material participation conclusive presumptions are correctly considered intra-period because each taxable period’s fulfillment of participation predicate factual requirements are mutually exclusive of any other period’s fulfillment of participation predicate factual requirements
*Recognize the Section 179(d)(5)(B) noncorporate lessor trade or business activity predicate factual requirements correctly qualify the Section 469(c)(1)(A) trade or business activity conclusive presumption and do not qualify the Section 469(c)(1)(B) material participation conclusive presumption
*Recognize the Section 469(c)(7)(B) rental real property trade or business activity predicate factual requirements correctly qualify the Section 469(c)(1)(A) trade or business activity conclusive presumption and do not qualify the Section 469(c)(1)(B) material participation conclusive presumption
*Recognize Section 469 references to activity conclusive presumption taxpayers correctly refers to Section 7701(14) taxpayers (taxpayers subject to either subtitle A or C internal revenue taxes) and not Section 469(a)(2) taxpayers (taxpayers subject to subtitle A internal revenue taxes)
*Recognize Section 469(c)(7)(B)’s activity conclusive presumption predicate factual requirements correctly demarcates Congress’s bright line distinction between trade or business activity labor and capital factors of production and investment activity capital factors of production
*The definition of a conclusive presumption and its significance in tax law
*The Section 469(c)(1)(A) trade or business activity conclusive presumption
*Common law trade or business activity conclusive presumption predicate factual requirements
*The Section 469(c)(1)(B) material participation conclusive presumption
*The Section 469(h)(1) participation conclusive presumption predicate factual requirements
*Congress’s periodic qualification of trade or business activity conclusive presumptions
*The Section 469(c)(7) rental real estate trade or business activity conclusive presumption and related predicate factual requirements
David Randall Jenkins
Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417. Web site: www.nasba.org
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