IRC §469(c)(7) Documentation

Where Work
Becomes Proof.

RepTrack is the AI-powered documentation platform for high-income real estate professionals. Capture every activity, prove every hour, and walk into any IRS audit with an airtight record.

Start Free Trial See how it works
750
Hours required
3.8%
NIIT you avoid
12
IRS rules tracked
$0
Advice given
RepTrack · Maria Rodriguez · 2024
◈ Supervised HVAC inspection at Butler St — about 90 minutes
✓ Filing under Vendor Coordination
Direct oversight of licensed contractor at owned rental property. 90 minutes logged.
RE Hours Filed 842 / 750 hrs
50% Test 67.3% ✓
Audit Readiness 84 · STRONG
Flags to Review 2 entries
Both Criteria ✦ MET
Contemporaneous Logs
750-Hour Tracking
50% Time Test
Material Participation
NIIT Elimination
IRS Flag Detection
CPA Partner Portal
Audit Readiness Score
AI Documentation Assistant
Whisper Voice Input
Contemporaneous Logs
750-Hour Tracking
50% Time Test
Material Participation
NIIT Elimination
IRS Flag Detection
CPA Partner Portal
Audit Readiness Score
AI Documentation Assistant
Whisper Voice Input
The Problem

High earners lose REP status
not because they didn't work —
because they can't prove it.

The IRS places the entire burden of proof on you. Without a contemporaneous, organized record, even legitimate participation gets denied in audit.

01
No contemporaneous log
Reconstructed logs created at tax time are routinely rejected by IRS examiners. Courts have consistently ruled against taxpayers who couldn't show daily or weekly records.
02
Investor hours counted by mistake
Reviewing P&Ls, attending investor meetings, monitoring performance — none of these count. Taxpayers routinely inflate hours with investor activities that the IRS specifically excludes.
03
W-2 job kills the 50% test
A physician working 2,000 W-2 hours needs 2,001+ RE hours just to pass the 50% test. Most high earners fail here and never realize it until audit.
How It Works

Three steps to audit-ready
documentation

RepTrack works the way you actually work — tell it what you did, and it handles the filing, categorization, and IRS flag detection.

01
◈
Tell the assistant what you did
Type or speak. The AI assistant understands real estate activities — it knows the difference between a qualifying property management call and a non-qualifying investor meeting. It files automatically.
02
⚑
Get flagged before it's a problem
RepTrack detects 6 IRS risk patterns in real time — investor activity, W-2 employee hours, third-party property manager risk, reconstructed logs, and more. Flags appear before you file.
03
⚖
Share with your CPA, defend anything
Your CPA logs in to their portal and sees every client's audit readiness score, flagged entries, and complete time log. One click generates an IRS documentation package.
Features

Every tool the IRS
expects you to have

⚑
Rules Engine
12 IRS rules for high-income earners, fully explained, with your live data mapped against each one. Know your audit risk before your CPA does.
IRC §469(c)(7) NIIT §1411 Material Participation Grouping Election
  • 750-Hour Test with live progress tracking
  • 50% of Work Time test — W-2 aware
  • Investor Activity exclusion detector
  • W-2 Employee Hours rule (>5% ownership)
  • Third-Party Property Manager risk flag
  • 3.8% NIIT threshold calculator
  • STR Bypass explanation (≤7-day avg stay)
  • MFJ Spouse rules — hours cannot be combined
◉
Audit Readiness Score
An 8-factor score (0–100) computed from your actual data. Hours filed, log consistency, flag count, criteria status, documentation density — all in one number.
Live score 8 factors Green / amber / red
🎙
Whisper Voice Input
Log activities by speaking. OpenAI Whisper transcription is tuned for real estate terminology — IRC 469, cost segregation, material participation, and more are spelled correctly.
OpenAI Whisper RE-domain prompt Mobile-ready
⊟
Time Log with IRS Flags
Every entry is automatically categorized across 12 IRS activity types. Entries with risk flags show a warning badge and a plain-language note for your CPA. Exportable to CSV or IRS package.
12 categories 6 flag types CSV + PDF export
⇄
MFJ Spouse Sync
For Married Filing Jointly couples, track both spouses' logs independently. The platform enforces the IRS rule: hours cannot be combined for the 750-hr or 50% tests, but do count for material participation.
MFJ rules enforced Separate logs Color-coded views
✉
Communications Hub
Every email you send about your properties is part of your documentation. The AI drafts professional communications to tenants, vendors, and contractors — and files them in your record.
AI-drafted Sent log Audit trail
Built for High-Income Earners

The stakes are different
when your W-2 is $500K

The higher your income, the more the IRS scrutinizes your REP claim — and the more documentation quality matters. RepTrack is built for the scenarios that actually affect high earners.

$
NIIT elimination
At $600K W-2 income + $80K rental income, you owe $3,040/yr in NIIT alone. REP status eliminates it — but only with documentation to back the claim.
⊘
$25K offset is worthless above $150K MAGI
The passive loss allowance phases out completely at $150K MAGI. Every high earner needs full REP status — not the active participation workaround.
⚡
Cost segregation without REP = trapped losses
Cost segregation generates large paper losses — but without REP status above $150K MAGI, they're suspended indefinitely. RepTrack helps you prove the status that unlocks them.
Annual Tax Impact · Example Scenarios
Physician, $600K W-2, 4 rentals
With REP status + cost seg
−$142K
taxable income reduction
Same physician without REP
Losses suspended, NIIT applies
$0
benefit — all losses trapped
NIIT on $80K rental income
MFJ over $250K MAGI threshold
+$3,040
per year without REP
RepTrack does not give tax advice. These figures are illustrative examples only. Consult your CPA or tax attorney for advice specific to your situation.
CPA Partner Portal

Give your CPA
the full picture

CPAs get a dedicated portal to review all their RepTrack clients — audit scores, flagged entries, communications on file, and one-click IRS package export. No more emailing spreadsheets.

⚖
Multi-client dashboard
See all clients' audit readiness scores, flag counts, hours, and criteria status in one view. Filter by status: complete, active, needs attention.
↓
One-click IRS package
Download a complete documentation package for any client — all entries, criteria status, flag summary, communications, and session notes. Formatted for IRS review.
◎
Read-only, secure access
CPAs can review but never edit client data. Every access is logged. Clients control which CPAs can see their account.
CPA Portal · 4 Clients ● Live
4
CLIENTS
2
COMPLETE
1
REVIEW
1
ATTN
Maria & Dr. Carlos Rodriguez
MFJ · Maria qualifier · 842 hrs · 2024
84 STRONG
Sandra & Mark Okonkwo
MFJ · Sandra qualifier · 798 hrs · 2024
79 GOOD
James Whitfield
Single · 621 hrs · 2024 · ⚑ 3 flags
58 REVIEW
Priya & Dev Sharma
MFJ · Priya qualifier · 402 hrs · 2024
31 ATTN
From The Field

What documentation
actually looks like in audit

My client came in with 847 hours of contemporaneous logs, every entry timestamped, every investor-activity flag already identified and explained. The examiner closed the case in one session.

Patricia M., CPA
Real estate tax practice · Chicago, IL

I'm a hospitalist. I used to log my RE hours in a spreadsheet on Sunday nights. My CPA told me that was a problem. RepTrack fixed it — I log on my phone after every activity.

Dr. James K.
Physician · 6 rental properties · Pittsburgh, PA

The investor activity flag caught something I didn't even realize was a problem — I'd been logging my monthly portfolio review calls as management hours for three years.

Sandra O.
Attorney · 4 rental properties · Atlanta, GA
Pricing

One platform. Two users.
Zero guesswork at audit.

Start free. No credit card required. Cancel anytime.

Starter
$49/mo
For individual real estate investors building their documentation practice from scratch.
AI documentation assistant
Whisper voice input
Time log with IRS flag detection
1 qualifying taxpayer
Up to 10 properties
CSV export
Rules Engine (all 12 rules)
Start Free Trial
Most Popular
Professional
$99/mo
For high-income earners with active portfolios and a CPA relationship that needs documentation support.
Everything in Starter
MFJ Spouse Sync (2 logs)
Unlimited properties
CPA portal access (1 CPA)
IRS documentation package (PDF)
Document uploads (receipts, contracts)
Audit Readiness Score
Weekly documentation reminders
Start Free Trial
CPA Firm
$199/mo
For CPA practices serving multiple REP clients. Manage all clients from one portal.
Everything in Professional
Unlimited client accounts
Multi-client dashboard
Bulk IRS package export
CPA review notes on entries
Priority support
Dedicated onboarding
Contact Sales
Start Today

Capture the work.
Prove the time.
Defend the claim.

The IRS audit starts with your time log. Make sure yours is ready.

Start Your Free Trial Book a Demo

RepTrack is a documentation and organizational platform. It does not provide tax, legal, or financial advice. All IRS rules shown are for informational purposes only. Consult your CPA or tax attorney.