Gale Chan

Gale Chan

McDermott Will & Emery

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Proposed Regulations Clarify Definition of “Real Property” for Real Estate Investment Trusts

On May 9, 2014, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 856 of the Internal Revenue Code (the Code) to clarify the definition of...more

5/23/2014 - Business Assets C-Corporation IRS Private Letter Rulings Proposed Regulation Real Estate Investments REIT U.S. Treasury

IRS Lacks Authority to Issue and Enforce Tax Return Preparer Regulations

On February 11, 2014, the U.S. Court of Appeals for the District of Columbia upheld the decision of the District Court for the District of Columbia, affirming that the Internal Revenue Service (IRS) lacked the authority to...more

2/21/2014 - IRS Tax Preparers Tax Returns

Senate Finance Committee Tax Reform Proposal Streamlines Energy Tax Credits

On December 18, 2013, Senate Finance Committee Chairman Max Baucus (D-MT) released a proposal that would streamline energy tax incentives to make them more predictable and technology neutral. The proposal would consolidate...more

2/7/2014 - Carbon Capture and Sequestration Clean Energy Coal Energy Energy Tax Incentives EPA Greenhouse Gas Emissions Internal Revenue Code Investment Tax Credits Nuclear Power Production Tax Credit Tax Reform Utilities Sector Wind Power

Section 752 Proposed Regulations Regarding Partnership Recourse Liabilities and Rules for Related Persons

On December 13, 2013, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations under Section 752 regarding recourse liabilities of a partnership and the special rules for related persons...more

1/28/2014 - IRS Partnerships Proposed Regulation Risk of Loss U.S. Treasury

Safe Harbors for Rehabilitation Tax Credits

On December 30, 2013, the Internal Revenue Service issued much anticipated guidance, in the form of Revenue Procedure 2014-12, providing a safe harbor under which it will not challenge a partnership’s allocations of...more

1/16/2014 - IRS Rehabilitation Benefits Safe Harbors Tax Credits

IRS Issues Additional Guidance on When Construction Begins for Purposes of Production Tax Credit, Investment Tax Credit

The Internal Revenue Service (IRS) has issued additional guidance relating to when construction begins with respect to wind and other qualified facilities for purposes of the production tax credit and investment tax credit. ...more

9/26/2013 - Investment Tax Credits IRS Production Tax Credit Renewable Energy Safe Harbors Wind Power

IRS Issues Notice to Determine When Construction Begins for Purposes of Production Tax Credit, Investment Tax Credit

The Internal Revenue Service (IRS) has issued important guidance to determine when construction begins with respect to a qualified facility for purposes of the production tax credit and the investment tax credit for certain...more

4/23/2013 - Investment Tax Credits IRS Production Tax Credit Safe Harbors Tax Credits

Key Energy-Related Tax Provisions in the 2014 Budget Proposal

President Obama’s recently released budget proposal for the 2014 fiscal year contains energy-related tax provisions that include a permanent extension of the renewable energy production tax credit (PTC) and a provision making...more

4/23/2013 - Derivatives Energy Tax Incentives Federal Budget Investment Tax Credits New Market Tax Credits Production Tax Credit Tax Credits

District Court Holds IRS Lacks Authority to Issue and Enforce Tax Return Preparer Regulations

On January 18, 2013, the District Court for the District of Columbia held that the Internal Revenue Service lacked the authority to issue and enforce the tax return preparer regulations that it issued in 2011 and permanently...more

1/24/2013 - Enforcement IRS Lack of Authority Permanent Injunctions Tax Preparers

Key Energy Tax Provisions Included in ‘Fiscal Cliff’ Legislation

On January 1, 2013, Congress passed the American Taxpayer Relief Act of 2012 to address the tax rate hikes and expiring tax incentives to avert the “fiscal cliff.” President Obama signed the legislation into law on January...more

1/4/2013 - American Taxpayer Relief Act Fiscal Cliff Investment Tax Credits New Market Tax Credits Production Tax Credit Renewable Energy Wind Power

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