we are currently a Partnership owning rental properties and have 7 partners.

The past 3 years were low and lots of tenants moved out and away from the city and downtown Orlando, therefore we have been operating at a loss. Two partners are active and manage the apartment buildings and the other partners are passive. In 2023, we also expect to be in a loss position which will lower the shareholders basis below zero, what does this mean?

What are the loss limitation rules? Are they different for active verse passive partners? Should we switch to S Corporation? Are the tax law loss rules different or the same?