Total Credits: 3 including 3 Taxes - Technical
My October 2016 Journal of Taxation paper, “Section 469’s Activity and Participation Conclusive Presumptions,” makes clear the Tax Court’s March 2014 Aragona Trust decision distilled previously confused rental real property trade or business activity and material participation distinctions. This paper concludes Aragona Trust is procedurally retroactive, outlines transition practices, and calls for regulatory changes.
Syllabus
Lesson 1.
Introduction
Lesson 2.
Aragona Trust is Procedurally Retroactive
Lesson 3.
Pragmatic Transitioning Practices
Lesson 4.
The Call for Regulatory Change
Lesson 5.
Conclusion
**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 leighanne.conroy@acpen.com.
*Recognize the Tax Court’s March 2014 Aragona Trust decision should be correctly accorded retroactive treatment
*Recognize transition practices correctly involve amending all open-year returns that had reported Section 469(c)(7) rental real property trade or business activities inconsistent with Aragona Trust
*Recognize the Secretary of the Treasury has a duty, and the reasons therefor, to correctly revise Section 469 and 1402 regulations to be consistent with Aragona Trust’s tenets
*Section 469(c)(7) rental real estate trade or business activity and material participation conclusive presumptions
*Procedural retroactivity of court decisions and application to the Tax Court’s March 2014 Aragona Trust decision
*Transitioning from pre-Aragona Trust decision real estate professional practices to Section 469(c)(7) rental real estate trade or business activity and material participation conclusive presumption practices
*Call for Section 469 and 1402 regulatory changes
Jenkins_Credentials (0.09 MB) | 5 Pages | Available after Purchase |
Section 469(c)(7) _Slides (2.52 MB) | Available after Purchase |
Section 469(c)(7) _Article (1.54 MB) | Available after Purchase |
Important CPE Credit Instructions_READ BEFORE WEBCAST UPDATED (0.47 MB) | Available after Purchase |
IRS CE Credit Request Form (0.15 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 tucjenkins@aol.com.
This webcast is an intermediate continuing education webcast.
It is assumed the webcast participant has successfully completed the ACPEN/BPN webcast, “Section 469’s Activity and Participation Conclusive Presumptions”
None
*CPAs
*Attorneys
*Enrolled Agents
*Enrolled Retirement Plan Agents
*Self-directed Retirement Plan Fiduciaries, Custodians, and Administrators
*Self-directed Retirement Plan Account Holders
*Tax Return Preparers
10/24/2016
No
David Randall Jenkins
10/11/2016
Please contact Anne Taylor for any complaints. anne.taylor@acpen.com, (972-377-8199).
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 submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org
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