seems like disregarded LLC's are an exception to the exception for 163(j) to the actively participates" provision. Ie. disregarded entities are ignored and the owner of the entity is subject to the usual 163(j) rules
Spidell speaker disagreed w me.
"However, an interest in an entity is not considered held by a limited partner or a limited
entrepreneur if the individual directly owns an interest in the entity and:
• Actively participates in the management of the entity during the period at issue;
• Has a spouse, child, grandchild, or parent who actively participates in the management of
the entity during the period at issue; or
• Actively participated in the management of the entity for a minimum of five years.
(IRC §1256(e)(3)(C))""