On July 21, 2016, the IRS issued long-awaited regulations under Section 50 of the Internal Revenue Code (the “Code”) clarifying the manner in which “Section 50(d) Income” is to be recognized in lease pass-through investment...more
7/29/2016
/ Energy Sector ,
Energy Tax Incentives ,
Historical Rehabilitation ,
Income Taxes ,
Investment Property ,
Investment Tax Credits ,
IRS ,
Land Developers ,
Lessee ,
Partnerships ,
S-Corporation ,
Tax Credits
Tax practitioners often face this issue: client is a limited liability company taxed as a partnership for federal income tax purposes (“LLC”), and it wants to issue equity to a current employee (“Individual”) without...more
Please join us for the Spring Tax Forum to be held at the Williams Mullen Center on Thursday, May 12, 2016. Topics Include:
Contributions of Property to a Partnership: An Analysis of Section 704(c) Methods
Part II:...more
On December 16, 2014, the Senate voted 76-16 to pass H.R. 5771, the Tax Increase Prevention Act of 2014 (“TIPA”), which was passed by the House by a vote of 378-46 on December 3, 2014. TIPA would extend over fifty (50)...more
The Internal Revenue Service (“IRS”) released proposed regulations changing the analysis of whether a partner bears the economic risk of loss for a partnership liability under IRC Section 752. Also, the proposed regulations...more
On January 9, 2014, the Internal Revenue Service (“IRS”) issued a revised version of previously released Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit...more
The Internal Revenue Service (“IRS”) recently issued guidance in Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit partnerships under IRC Sec. 704(b). The...more
The United States Tax Court recently issued its opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15 (12/2/13), a ruling regarding allocations of income attributable to an unvested partnership interest. The...more