J. Conrad Garcia

J. Conrad Garcia

Williams Mullen

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U.S. Tax Court Ruling in State Conservation Tax Credit Case Requires Income Recognition

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 Companies Operating Agreements Partnerships Sale of Assets State Taxes Tax Credits Transfer Taxes Transfers

New Proposed Regulations Could Shake Up the Allocation of Partnership Debt

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

2/17/2014 - IRS Partnerships Proposed Regulation U.S. Treasury

Revised Rev. Proc. 2014-12 Clarifies New Guidance on Rehabilitation Tax Credits

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

1/13/2014 - IRC IRS Property Tax Rehabilitation Benefits Repairs Tax Benefits

IRS Issues Long-Awaited Guidance Regarding the Allocation of Federal Rehabilitation Tax Credits

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

1/3/2014 - IRS Rehabilitation Benefits Safety Precautions Tax Credits

Tax Court Ruling Impacts the Treatment of Income Allocations Attributable to Unvested Partnership Capital Interests

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

12/6/2013 - Business Taxes Corporate Taxes Income Taxes IRC Section 83(b) Partnerships

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