This ruling focused specifically on irrevocable grantor trusts commonly referred to as Intentionally Defective Grantor Trusts (IDGT).

As Michael said, it depends on if you got to the level of a trade or business when it comes to lending.Some important things that will determine this are1) The amount of loans you are originating on an annual basis2) What your intent is when forming this partnership3) The value of the loans you are originating compared4) etcBest of luck

Brie, ill call you back in a bit.

I live in the SF Bay Area and have decided to buy my first single-family home.I fully acknowledge and recognize that the SF Bay Area and California (in general) may have some of the worst cash flow numbers in the entire country.I've already traveled to cheaper Midwestern states to look at real estate opportunities, but have decided to invest here in the SF Bay Area as I'm purchasing with the intention of living in it first and foremost, and then renting it out sometime in the near future when I move overseas.I'm looking for anywhere in the Greater Bay Area/Northern California region (even Sacramento & Central Valley is okay) with better than average purchase price to rent ratio, and some appreciation (if possible). 

It typically takes 4 to 6 months to produce on a part-time basis and my intention is that it will be of value to those in the industry, including me and a prospective mentor.

That usually lets the county types know they could be helping an owner and not tracking someone down with ill intentions.Be open and honest and you won't go wrong. :)

We have a 14-page management contract that we've added our real experiences to over the years, with the intent of protecting both us AND the landlord.

I definitely could have worded the question better and have no intention of ever discriminating  against anyone. 

Finally, to answer your other comments, I think the exact right answer depends on your future intentions.

If I were doing it I would address the things I want in a letter of intent, non binding.