Generally, one or more trade or business activities or rental activities may be treated as a single activity if the activities make up an appropriate economic unit for the measurement of gain or loss under the passive activity rules.
Whether activities make up an appropriate economic unit depends on all the relevant facts and circumstances. The factors given the greatest weight in determining whether activities make up an appropriate economic unit are:
Similarities and differences in types of trades or businesses,
The extent of common control,
The extent of common ownership,
Geographical location, and
Interdependencies between or among the activities.
Example.
You have a significant ownership interest in a bakery and a movie theater in Baltimore and in a bakery and a movie theater in Philadelphia. Depending on all the relevant facts and circumstances, there may be more than one reasonable method for grouping your activities. For instance, the following groupings may or may not be permissible.
A single activity.
A movie theater activity and a bakery activity.
A Baltimore activity and a Philadelphia activity.
Four separate activities.
Once you choose a grouping under these rules, you must continue using that grouping in later tax years unless it’s determined that the original grouping was clearly inappropriate or a material change in the facts and circumstances makes it clearly inappropriate.
The IRS may regroup your activities if your grouping fails to reflect one or more appropriate economic units and one of the primary purposes of your grouping is to avoid the passive activity limitations.
有个白玉房这几年都是负的loss,,报税的会计说，一般每个房子的loss都是自己carryover,直到这个房子赚钱去互抵，如果想和别的出租房的正赢利相抵，就需要选择choose to treat all properties as one。
请问一下这两种选择哪个更合适？选择绑定，还是分开算好？大家都怎么选？
下面这个节选分析了你可以根据你自己的情况分割合并计算自己的生意，比如按类型，按地区，或者都合在一起。
自己看一下，不懂再来问。
https://www.irs.gov/instructions/i8582
Grouping of ActivitiesGenerally, one or more trade or business activities or rental activities may be treated as a single activity if the activities make up an appropriate economic unit for the measurement of gain or loss under the passive activity rules.
Whether activities make up an appropriate economic unit depends on all the relevant facts and circumstances. The factors given the greatest weight in determining whether activities make up an appropriate economic unit are:
Similarities and differences in types of trades or businesses,
The extent of common control,
The extent of common ownership,
Geographical location, and
Interdependencies between or among the activities.
Example.
You have a significant ownership interest in a bakery and a movie theater in Baltimore and in a bakery and a movie theater in Philadelphia. Depending on all the relevant facts and circumstances, there may be more than one reasonable method for grouping your activities. For instance, the following groupings may or may not be permissible.
A single activity.
A movie theater activity and a bakery activity.
A Baltimore activity and a Philadelphia activity.
Four separate activities.
Once you choose a grouping under these rules, you must continue using that grouping in later tax years unless it’s determined that the original grouping was clearly inappropriate or a material change in the facts and circumstances makes it clearly inappropriate.
The IRS may regroup your activities if your grouping fails to reflect one or more appropriate economic units and one of the primary purposes of your grouping is to avoid the passive activity limitations.
一个房子买的时间长，贷款利息少了，净利润多要交税；另一个房子刚刚买，贷款利息多，有loss。这两个房子就互相对冲，灵活啊。