- 13 -
temporary regulations), providing that “any work done by an
individual * * * in connection with an activity in which the
individual owns (directly or indirectly, other than through a C
corporation) an interest at the time the work is done shall be
treated for purposes of this section as participation of such
individual in the activity.” One year later, in 1989, the
Secretary prescribed section 1.469-4T(b)(2)(ii)(B), Temporary
Income Tax Regs., 54 Fed. Reg. 20527, 20543 (May 12, 1989) (the
1989 temporary regulations), providing that “For purposes of
applying section 469 and the regulations thereunder, a taxpayer’s
activities do not include operations that a taxpayer conducts
through one or more entities (other than passthrough entities).”
As part of the regulatory project underlying the 1989
temporary regulations, the Secretary also amended the 1988
temporary regulations (the amended 1988 temporary regulations) to
delete the parenthetical exception “(directly or indirectly,
other than through a C corporation)” from section 1.469-5T(f)(1),
Temporary Income Tax Regs. Sec. 1.469-5T(f)(1), Temporary Income
Tax Regs. On May 15, 1992, the Secretary finalized the amended
1988 temporary regulations as section 1.469-5(f)(1), Income Tax
Regs. (the 1992 final regulations), leaving them virtually
unchanged in their final form. Two years later, in 1994, the
Secretary finalized a substantially revised version of the 1992
proposed regulations as section 1.469-4, Income Tax Regs. (the
1994 final regulations).
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011