Real Estate Professional Tax Loophole - holdings in a trust

[Mark Dante]

Question for the CPA's - Person A is setting up a trust for estate planning purposes.  Person B will be the beneficiary of that trust upon the death of Person A.  The assets of the trust are primarily income producing real estate and are all free and clear.  (Not sure if this matters, but there is also stock/cash in the trust.)  Is there anything that would prevent Person B (who manages, draws income, etc. from the trust assets) from obtaining status as a Real Estate Professional under the tax code?  Does the fact that assets are in trust affect this?  ( Let's assume that the trust gives Person B the power/authority to leverage the current assets and borrower against the currently existing assets thereby allowing Person B to acquire additional real estate.)