The IRS has released 26 CFR Part 1, resolving questions regarding the five-year period to claim rehabilitation credits for qualified rehabilitation buildings (QRBs). Prior to the proposed regulation, practitioners were...more
In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more
4/22/2014
/ Conservation Tax Credit ,
Corporate Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Operating Agreements ,
Partnerships ,
Sale of Assets ,
State Taxes ,
Tax Credits ,
Transfer Taxes ,
Transfers
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