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Level 2
February 22, 2026
Question

Section 469 Grouping Election – Rental LLC & S Corp with Common Owner (Reporting on 8825 or 1065?)

  • February 22, 2026
  • 1 reply
  • 6 views

We have the following situation:

  • One Rental LLC filing Form 1065

  • One S Corporation filing Form 1120-S

  • Both entities are owned 100% by the same individual

  • The S Corporation is the tenant of the Rental LLC

The shareholder intends to make a Section 469 grouping election to group the rental activity with the operating activity for passive activity loss purposes.

My question is regarding entity-level reporting:

Even if the individual makes the Section 469 grouping election, should the Rental LLC still report rental income and expenses on Form 8825 (as part of Form 1065)?

Or does the grouping election allow the LLC to report the activity differently on Form 1065 (instead of using Form 8825)?

My understanding is that the grouping election is made at the individual level and does not change how the partnership reports the rental activity, but I would appreciate confirmation.

Thank you in advance for your guidance.

1 reply

qbteachmt
Level 15
February 22, 2026

"One Rental LLC filing Form 1065"

"owned 100% by the same individual"

Why is that on 1065?

"does not change how the partnership reports the rental activity"

How is that a partnership?

Don't yell at us; we're volunteers
NikhilAuthor
Level 2
February 27, 2026

Yes it is partnership and apologies there are two owners.