For passive activity loss limitation purposes, what have several court decisions clarified about a member of a multi member LLC who is an individual? a. The individual is treated as a limited partner when determining if the member can pass any of the material participation tests, b. The individual is treated as a general partner when determining if the member can pass any of the material participation tests, c. The individual can never pass any of the material participation tests, d. The individual is never subject to any of the PAL limitation rules.