The new Tax Cut and Jobs Act of 2017 (the “Act”) contains a provision that is of great importance to any persons buying or selling an interest in a partnership. New Section 864(c)(8) of the U.S. Internal Revenue Code (the...more
On December 30, 2013, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2014-12, which sets out a new “safe harbor” for allocations of the historical rehabilitation credit (the “HRC”) among partners in a...more