Hi Chanan, First thanks for stopping by and sharing your thoughts.

Second with regard to Sec 267, I think the chunk you’re thinking about (Section 267(a)(2)?) says the accounting methods of the related parties need to match. Specifically the bit at 267(a)(2)(A):

(A)by reason of the method of accounting of the person to whom the payment is to be made, the amount thereof is not (unless paid) includible in the gross income of such person…

Third, with regard to the self-rental rule, I think we agree? E.g., if Tom, Dick and Harry respectively own 70%, 20% and 10% of a little manufacturing business (say organized as an S corporation) and then they buy a building (say organized as an LLC treated as a partnership) and the ownership percentages of Tom, Dick and Harry there are 70%, 20% and 10%, I think all owners can add a grouping statement to their 1040 returns. E.g., Harry the 10% owner of the S corporation and the building partnership can take building depreciation losses on his 1040.

Unless the property owner is only a minority owner of the entity.

But this should still work if you have a minority interest in the entity