Participation
(6) Participation. The following rules apply to multiple activities (the separate activities) that would be treated as a single activity (the original activity) if the taxpayer's activities were determined without regard to this paragraph (o): (i) The taxpayer shall be treated as materially participating (within the meaning of 1.469-5T) for the taxable year in the separate activities if and only if the taxpayer would, but for the application of this paragraph (o), be treated as materially participating for the taxable year in the original activity. (ii) The taxpayer shall be treated as significantly participating (within the meaning of 1.469-5T(c)(2)) for the taxable year in the separate activities if and only if the taxpayer would, but for the application of this paragraph (o), be treated as significantly participating for the taxable year in the original activity. (7) Election(i) In general. A person makes an election with respect to an undertaking under this paragraph (o) by attaching the written statement described in paragraph (o)(7)(ii) of this section to such person's return for the taxable year for which the election is made (see paragraph (o)(2) of this section). (ii) Written statement. The written statement required by paragraph (o)(7)(i) of this section must (A) State the name, address, and taxpayer identification number of the person making the election; (B) Contain a declaration that an election is being made under 1.469-4T(o); (C) Identify the undertaking with respect to which such election is being made; and (D) Identify the remainder of the activity in which such undertaking would otherwise be included. (8) Examples. The following examples illustrate the application of this paragraph (o):