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At-risk limits apply to any taxpayer who is somehow shielded from losing money (by using some form
of non-recourse financing) in an investment regardless of whether the taxpayer is a individual
, or a corporation. It is rare that at-risk limits apply to individuals (because non-recourse financing is not easy to get) but the limits can apply to any and all taxpaying entities who have financed their investment with non-recourse financing.
Special loss allowance
only applies to taxpayers who are in the business of renting residential real estate. Real estate rentals are always considered passive activities
, but the special loss allowance applies if:
1.) Taxpayer owns 10% or more of the rental property
2.) The taxpayer is actively engaged in the management of their rental property
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