On January 19, 2017, the IRS released an advance version of Revenue Procedure 2017-19, which provides a safe harbor (the "Safe Harbor") under which the IRS will not challenge the treatment of an Energy Savings Performance...more
On January 18, 2017, the IRS released proposed regulations (the "Proposed Regulations") to implement Section 1101 of the Bipartisan Budget Act of 2015 (BBA),1 which replaces the current rules governing partnership...more
On December 15, 2016, the IRS issued Notice 2017-04, which clarifies and extends certain "begun construction" requirements for facilities qualifying for the Section 45 production tax credit (PTC) for which construction must...more
On August 30, 2016, the IRS issued final regulations that clarify and expand the definition of "real property" for purposes of qualifying as a real estate investment trust (REIT). The final regulations substantially follow...more
On July 21, 2016, the IRS released temporary regulations section 1.50-1T under IRC Section 50(d)(5) of the Internal Revenue Code (the "Temporary Regulations") (TD 9776) that provide guidance regarding: (1) the income...more
Following last year's extension of the investment tax credit for qualifying projects for which construction begins prior to January 1, 2020, and of the production tax credit (PTC) with respect to certain facilities the...more
Earlier today, President Obama signed the Military Construction and Veterans Affairs and Related Agencies Appropriations Act, 2016 (the Act)—which includes the Consolidated Appropriations Act of 2016 and the Protecting...more
On November 2, 2015, President Obama signed into law the "Bipartisan Budget Act of 2015" (P.L. 114-74). Among other things, the act eliminates the TEFRA unified partnership rules and the electing large partnership rules, and...more
Earlier yesterday, the IRS released Notice 2015-25, 2015-13 IRB 1, which updates the guidance provided in Notice 2013-29, 2013-1 C.B. 1085, Notice 2013-60, 2013-2 C.B. 431, and Notice 2014-46, 2014-36 I.R.B. 520...more
Earlier today, President Obama signed the Tax Increase Prevention Act of 2014 (H.R. 5771) into law, following its passage through Congress on Tuesday. Among other things, the act will provide a one-year retroactive extension...more
On August 8, 2014, the Internal Revenue Service (IRS) issued Notice 2014-46, which clarifies and modifies Notice 2013-29 and Notice 2013-60....more
8/12/2014
On May 9, 2014, the Internal Revenue Service (IRS) issued proposed regulations that clarify the definition of real property for purposes of the real estate investment trust (REIT) provisions of the Internal Revenue Code....more
Following Historic Boardwalk Hall LLC v. Commissioner, 694 F.3d 425 (3d Cir. 2012), which rejected a partnership's allocation of rehabilitation tax credits to a purported partner, the Internal Revenue Service (IRS) recently...more
1/8/2014
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Historical Landmarks ,
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Partnerships ,
Real Estate Holding Companies ,
Real Estate Market ,
Renovations ,
Safe Harbors ,
Tax Credits ,
Wind Power
On September 20, 2013, the IRS released Notice 2013-60, which clarified Notice 2013-29. Each Notice addresses the requirement that construction of a qualified facility must begin before January 1, 2014, in order to be...more