Taxpayers Affected

Individuals Trusts Estates	No Exceptions
Partnerships (general, limited) Entities taxed as partnerships (e.g. LLC) S Corporation	If entity "marterially participates" (normal), apply rules to individual owners (shareholders, partners, etc.). If entity does not materially participate, activity is passive with respect to entity and to all owners with respect to their passed-through income/loss.
Personal Services C Corporation	No exceptions
Closely Held C Corporation	Can offset passive income against active income, but not portfolio income.