The Virginia Historic Rehabilitation Tax Credit (HRTC) program (see Virginia Code § 58.1-339.2) has played a significant role in stimulating Virginia’s economy and preserving thousands of historic properties throughout the...more
Join Williams Mullen partners for our in-person Winter Tax Forum on Wednesday, January 31, 2024. Our speakers, Farhad Aghdami, Jenny Connors, Conrad Garcia and Beth Hungate-Noland will present on partnership aggregators and...more
On October 31, 2022, the Virginia Department of Taxation (the “Department”) released draft guidance (the “Draft Guidelines”) on Virginia’s elective pass-through entity (PTE) tax, addressing how to make a PTE tax election for...more
During the 2022 General Assembly Session, legislation was enacted that allows a qualifying pass-through entity (PTE) to make an annual election for Taxable Years 2021 through 2025 to pay income tax at a rate of 5.75% at the...more
On March 1, 2021, the Virginia General Assembly approved legislation creating the Virginia Opportunity Tax Credit Program (Program), a new state low-income housing tax credit (LIHTC) that contributes an amount to a qualified...more
On Thursday March 11, President Biden signed the American Rescue Plan Act of 2021 (the “Act”) into law. The $1.9 trillion Act includes COVID-19 relief, as well as broader stimulus, but also includes several revenue-raising...more
The IRS has released 26 CFR Part 1, resolving questions regarding the five-year period to claim rehabilitation credits for qualified rehabilitation buildings (QRBs). Prior to the proposed regulation, practitioners were...more
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 Company (LLC) ,
Operating Agreements ,
Partnerships ,
Sale of Assets ,
State Taxes ,
Tax Credits ,
Transfer Taxes ,
Transfers
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