We require that rent not exceed 50%, but if the source of income in non-taxable we allow 59%.  

If A invests $150,000 in a new vessel, taxable gain to the extent of $50,000 would be recognized.

If it's taxed as a partnership for federal income tax purposes "constructive receipt" shouldn't be used to describe distributions from a partnership as distributions generally are intrinsically not a taxable event. 

I'm not sure if Total Income or Taxable Income is used to determine whether one is an accredited investor, but my understanding is that it's Total Income. 

Example; 2019 you showed 120K in taxable income, so your P&L should reflect 10K or more a month and those 3 months of bank statements should support the P&L.

I read "The capital gains on the sale of your primary residence in France are not taxable, which is a significant difference from the US taxation of primary residences."

When the sale of a rental property is a taxable event, then the accrued passive losses for that property can be used to offset your other ordinary income without regard to the $25K cap on the net passive loss allowance.Sorry if this is not entirely clear, but answer is not as simple as the earlier posters suggested.

You pay income taxes on net taxable income.

Only the $15k profit (minus any commissions, fees, or other selling costs.) will be taxable. 

So, if you find that you do have a taxable gain large enough to worry about, I think you would qualify for a 1031 Exchange.