14-Apr-2019 3:37pm
(v) The trades or businesses to be aggregated satisfy at least two of the following factors (based on all of the facts and circumstances):
(A) The trades or businesses provide products, property, or services that are the same or customarily offered together.
(B) The trades or businesses share facilities or share significant centralized business elements, such as personnel, accounting, legal, manufacturing, purchasing, human resources, or information technology resources.
(C) The trades or businesses are operated in coordination with, or reliance upon, one or more of the businesses in the aggregated group (for example, supply chain interdependencies).
15-Apr-2019 11:21am
17-Apr-2019 9:03am
17-Apr-2019 1:36pm
Supply chain interdependencies - the rental properties need a property manager to operate.
17-Apr-2019 2:09pm
17-Apr-2019 2:57pm
17-Apr-2019 8:24pm
I am not following how he pays or in this case, doesn't pay, himself for the services provided to himself is part of this determination.
This arrangement happened before TCJA but I aggregated the two with the belief that B and C at the very least was satisfied.
18-Apr-2019 10:35am
18-Apr-2019 11:08am
There is a real Sch C.
I just want to know if, that were the case, you would agree to the aggregation.
18-Apr-2019 11:11am