Here are the rules. Interpretation is up to you and your professional tax adviser. As far as I'm concerned, you are correct that the PM company, as your contractor, would have their hours counted toward your QBI record keeping hour to meet the safe harbor.
04 Rental services. Rental services for purpose of this revenue procedure include: (i) advertising to rent or lease the real estate; (ii) negotiating and executing
leases; (iii) verifying information contained in prospective tenant applications; (iv) collection of rent; (v) daily operation, maintenance, and repair of the property; (vi) management of the real estate; (vii) purchase of materials; and (viii) supervision of
employees and independent contractors. Rental services may be performed by owners or by employees, agents, and/or independent contractors of the owners. The term
rental services does not include financial or investment management activities, such as arranging financing; procuring property; studying and reviewing financial statements or reports on operations; planning, managing, or constructing long-term capital improvements; or hours spent traveling to and from the real estate.
Source: www.irs.gov/pub/irs-drop/n-19-07.pdf
Good news: 2018 is a 'free pass' year in terms of providing records, at least according to my friend who is an IRS auditor. Neither one of us will be coming to defend you in the event of an audit though, so proceed according to your own thoughts and after consulting a competent Pro for advice.
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