1.469-2T(f) "sets forth rules that require income from certain passive activities to be treated as income that is not from a passive activity (regardless of whether such income is treated as passive activity gross income
under section 469 or any other provision of the regulations thereunder)." Note that the income is recharacterized, but the classification of the activity as a passive activity is not altered.
If the rules apply, the passive activity gross income
and passive activity deductions from that activity are determined under the following rules: (1) the applicable percentage of each item of the taxpayer's income for the taxable year from interest charged to the borrowing entity is treated as passive activity gross income
from the activity; and (2) the applicable percentage of each deduction for the taxable year for interest expense that is properly allocable to the taxpayer's income from the interest charged to the borrowing entity is treated as a passive activity deduction from the activity.
Rental Deductions $100,000 Less: Passive activity gross income
(50,000) Net active income (30,000) Suspended passive activity loss $ 20,000