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Framework for Tax Reform Released

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means, and the Senate Committee on Finance released a unified framework (the Framework) with the stated goal of achieving pro-American,...more

Trump Administration Releases Blueprint of Tax Reform

On April 26, 2017, the Trump Administration announced a blueprint of tax reform principles that is described as “The Biggest Individual and Business Tax Cut In American History.” The Administration identified four goals for...more

[Event] Spring 2016 Tax Forum - May 12th, 8:00 am, Richmond, VA

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

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

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

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

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

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

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