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HOME GLOSSARY MATERIAL PARTICIPATION · VOLUME I · 2026 EDITION
GLOSSARY ENTRY · DEFINED TERM

Material Participation

The IRC §469 test for whether a taxpayer is non-passive in a trade or business. Treas. Reg. §1.469-5T(a) provides seven tests; satisfying any one is sufficient. The most-used: >500 hours in the activity, or >100 hours and more than any other individual.

STATUTE BASIS · IRC §469 · Treas. Reg. §1.469-5T(a)

In context

The seven material participation tests under Treas. Reg. §1.469-5T(a):

  1. >500 hours in the activity during the tax year
  2. Substantially all of the activity participation is by the taxpayer
  3. >100 hours and more than any other individual
  4. Significant participation activity (>100 hours) aggregating to >500 hours
  5. Material participation in the activity for any 5 of the prior 10 years
  6. Personal service activity with material participation in any 3 prior years
  7. Facts and circumstances — regular, continuous, and substantial participation

For STR operators, test 3 is the typical qualification: 100+ hours of personal management (bookings, communications, cleaning oversight, maintenance) with no third-party manager exceeding that time.

For REPS taxpayers with multiple rental properties, the §469(c)(7)(A) aggregation election is typically required — without it, material participation must be tested separately for each property.

See /passive-activity/ for the topic hub.