Charles Purcell

Charles Purcell

K&L Gates LLP

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New Temporary Regulations Deny Basis Increase in Partnership Interests in Lease Passthrough ITC Structures

On July 21, the U.S. Treasury Department (“Treasury”) released temporary and proposed regulations denying a basis increase to equity holders of lessee partnerships and S corporations to account for mandatory income inclusions...more

7/26/2016 - Congressional Review Act Internal Revenue Code (IRC) Investment Tax Credits IRS Proposed Regulation S-Corporation U.S. Treasury

New Treasury Guidance Significantly Expands Field of Renewable Energy Projects That May Qualify for the PTC or ITC

On May 5, the U.S. Treasury Department released Notice 2016-31 to address certain changes made to the Production Tax Credit (“PTC”) and Investment Tax Credit (“ITC”) in the Protecting Americans from Tax Hikes (“PATH”) Act of...more

5/26/2016 - FERC Investment Tax Credits Production Tax Credit Protecting Americans from Tax Hikes (PATH) Act Renewable Energy

Investing in India? Take a Look at the Amended India-Mauritius Tax Treaty Before You Do

On May 10, 2016, India and Mauritius signed a protocol amending the India-Mauritius double income tax treaty that would, among other things, permit India to tax a Mauritian resident on capital gains arising from the sale of...more

5/23/2016 - Double Taxation Equity Investors Foreign Investment India

Tax Exclusions for Sale of Stock Issued by Qualified Small Business Corporations Becomes Permanent — At Least Temporarily

Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more

2/1/2016 - Capital Gains Gain Exclusion Investment Protecting Americans from Tax Hikes (PATH) Act Qualified Small Business Stock Small Business Startups Tax Planning

Tax Reform and the Timber Industry

This alert provides an overview of various timber tax issues in play as part of the tax reform debate. The alert is drawn from several sources, including former House Ways and Means Committee Chairman David Camp’s tax reform...more

2/16/2015 - Capital Gains Capitalization Corporate Taxes Dividends REIT Tax Reform Timber

New Guidance on Historical Rehabilitation Credits May Indicate Tougher Safe Harbors for Other Investment Tax Credits in the Future

On December 30, 2013, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2014-12, which sets out a new “safe harbor” for allocations of the historical rehabilitation credit (the “HRC”) among partners in a...more

1/15/2014 - Historical Rehabilitation IRS LLC Partnerships Safe Harbors Tax Credits

IRS Notice 2013-60 Clarifies Rules on Beginning of Construction

On September 20, 2013, the U.S. Department of the Treasury (“Treasury”) released Notice 2013-60, which clarifies in important ways the eligibility rules applicable to the investment tax credit (“ITC”) and production tax...more

9/25/2013 - American Taxpayer Relief Act Construction Contracts Investment Tax Credits IRS Production Tax Credit Tax Credits U.S. Treasury

Exclusion from Tax for Stock Issued by Qualified Small Business Corporations

On November 3, 2010 and January 18, 2011, we issued client alerts discussing the opportunities provided by the Section 1202 exclusion from tax on gain realized on the sale of certain stock issued by a “qualified small...more

2/4/2013 - American Taxpayer Relief Act Capital Gains Gain Exclusion Qualified Small Business Stock Small Business Startups

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