Grants in Lieu of Tax Credits Under the Tax Recovery Act - A square Peg in a Round Hole


Many issues are raised by the grant program and the guidance recently issued by Treasury, including the legal effect of the guidance, the resolution of disputes arising under the grant program, unanswered procedural questions under the program, and income tax issues relating to the treatment of grants. These areas of difficulty result from the imperfect fit of the grant program with the existing tax credit rules.

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