A client that is always seeking interesting ways of tax benefit due to being in second highest marginal tax bracket sent me an article about using Sec. 280A(g) to allow their partnership to rent their residence for up to 14 days, and gain tax-free income. The article they sent is over 8 years old, but I did find another article on the subject written in 2021.
Article sent by client dated 2012: http://gedeonlawcpa.com/how-to-write-off-14000-to-hold-business-meetings-in-your-home/
2021 article I found: https://andersonadvisors.com/section-280a-deduction-explained/
This sounds like serious manipulation of the IRC and I do not agree with the authors' positions. My interpretation of 280A(g) 14 day rental rule means the taxpayer that theoretically rents their house to the partnership CANNOT occupy the residence, and thus trigger personal use, during any of the rented days, per Sec. 280A(d)(1).
So, if the taxpayer whose house would be rented still occupies and uses the home for personal purposes during the 14 days, they do not qualify as "fair rental days" since personal use still exists.
Not to mention the absurd rental value comparatives to renting a hotel ballroom, for example, for what is ultimately a three member partnership.
Thoughts? I think this is complete nonsense but curious if anyone else interprets 280A language the same way it is discussed in the linked articles, or if my interpretation is on track.