Another thing to consider is that you can group the properties together by activity to qualify. However, you cannot group commercial and residential properties into the same activity under the safe harbor. So if you own a commercial building, a residential building, you need 250 hours for each activity. Note the hours requirement is not required under the safe harbor for 2018 so you could apply the safe harbor and have no hourly documentation just for 2018. Also if you pay a property manager, it is more likely to qualify. But I wonder if property managers will start billing each month with an hours summary, I mean that is literally what is needed. Then the taxpayer just hands over the billing slips to meet the 250 hours to IRS. Not likely that IRS will then go audit the property manager. I look forward to see how this affects the industry.
