Rental activity considered passive when passing the material participation tests? Shouldn't you be able to realize the rental loss against other income if you pass?

No, there is an AGI limitation. Your passive losses will accumulate until you sell.

If your modified adjusted gross income (see the instructions for line 6, later) is $100,000 or less ($50,000 or less if married filing separately), your loss is deductible up to the amount of the maximum special allowance referred to in the preceding paragraph.

If your modified adjusted gross income is more than $100,000 ($50,000 if married filing separately) but less than $150,000 ($75,000 if married filing separately), your special allowance is limited to 50% of the difference between $150,000 ($75,000 if married filing separately) and your modified adjusted gross income.

Generally, if your modified adjusted gross income is $150,000 or more ($75,000 or more if married filing separately), there is no special allowance.