At-Risk Rules (Section 465)

At-risk rules limit business loss deductions to the amount economically at risk, preventing deductions for losses funded by nonrecourse financing.

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Exam Tip

At-risk rules apply BEFORE passive activity rules. Qualified nonrecourse (real estate) counts as at risk. Form 6198.

What are At-Risk Rules?

Cannot deduct more than your actual economic investment.

Amount At Risk Includes

  • Cash contributions
  • Recourse debt (personally liable)
  • Qualified nonrecourse financing (real estate)

Does NOT Include

  • Nonrecourse debt (not personally liable)
  • Guarantees without true liability

Order of Application

At-risk rules apply BEFORE passive activity rules.

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