Rental income is always passive unless you spend 750+ hours doing it and are therefore considered a "real estate professional".
I see. These passive activity rules are for general business. Rental income is always passive unless you spend 750+ hours doing it and are therefore considered a "real estate professional".
Agreed that rental income is almost always passive, but under this definition your "flip business" can also be passive and therefore those passive gains from the (passive) flip activity can offset previously disallowed passive losses from rental activity.