HRC Guidance May Impact Other Investment Tax Credits

Law360, New York (January 21, 2014, 6:54 PM EST) -- On Dec. 30, 2013, the Internal Revenue Service released Revenue Procedure 2014-12, which sets out a new “safe harbor” for allocations of the historical rehabilitation credit (HRC) among partners in a partnership or members in a limited liability company (for purposes of this article, “members” of a “project company”).

The new safe harbor is intended to provide a degree of assurance regarding allocations of the HRC for investors in developer and lease pass-through (i.e., inverted lease) partnerships and LLC structures, including those using a “partnership flip”...
To view the full article, register now.
Law360 Pro Say Podcast
Check out Law360's new podcast, Pro Say, which offers a weekly recap of both the biggest stories and hidden gems from the world of law.