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Loophole

PAL Grouping Election (§469)

Group rentals with an active business to unlock suspended passive losses.

Overview

Under Reg §1.469-4, elect to group rental activities with a related trade/business as a single 'appropriate economic unit.' Suspended passive losses become deductible against the business income — unlocking losses that would otherwise be trapped until sale.

Best fit
Business owners with rentalsSuspended-loss holdersRelated-party leases
Estimated impact
Unlock 100% of trapped passive losses immediately

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