Recent Lessons On Partnership Tax Credit Allocations

Law360, New York (January 25, 2016, 11:57 AM EST) -- In its recently issued opinion in the case of Route 231 LLC v. Commissioner, No. 14-1983, (4th Cir. 2016), the U.S. Court of Appeals for the Fourth Circuit affirmed the U.S. Tax Court's decision finding that a transfer of state tax credits to a 1 percent member who had contributed $3.8 million to the company was a disguised sale requiring the taxpayer to recognize income from the transfer....

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