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”...
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