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Business

August 24, 2025

Significant Participation Activity

A significant participation activity (SPA) is a trade or business activity where you participate for more than 100 hours during the tax year, but your involvement doesn't meet the stricter "material participation" standards.

Example:

  • Renting out a property and spending over 100 hours on repairs and maintenance, but not managing tenants or day-to-day operations.

Tax Impact

  • Potential Reclassification: If your combined SPA hours across all activities exceed 500 in a year, the income from those activities can be reclassified as non-passive. This means you can offset losses with other income, but any gains are taxed at higher ordinary income rates.
  • Material Participation: Simply meeting the SPA threshold doesn't automatically qualify you for material participation. You still need to meet one of the defined tests for full tax benefits.

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References

§ 469 - Passive activity losses and credits limited