That said, since I'm not actively involved in it myself, I may not be the most credible voice on the topic.

They come to realize  fractional ownership in a semi-active project with far less control is not as advantageous and eliminates the ability to build the more personal and meaningful relationships with lenders that comes with going through the more natural progression of growing a portfolio and business. 

(REPS)A real estate professional for tax purposes is someone who materially participates in real estate trades or businesses, spending more than 750 hours a year and over half of their working time on real estate activities.

Are you actively buying while prices are stalled or acting as a PML currently?

It costs a little bit of money and it takes a little bit of time, but you will learn a lot (especially if you sign on with the right broker) and then you don't have to worry about the possibility of conducting unlicensed activity.

It sounds cheesy, but the best way to prepare is to work with a friend or two and role-play.

In your situation the OA is going to play a more substantial role because you have a partner.

If there's other activity going on in the s corp then that's a different story of course. 

I have an attorney working on the tax lien but it's still an active lien.

The key is when the property is available and actively marketed for rent.If the separation isn't completed until 2026, you could still deduct the portion of closing costs allocated to the rental unit at that time.