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01.29.14

IRS Issues Historic Tax Credit Guidance

In the Historic Boardwalk Hall case, the IRS successfully argued that the investor was too insulated against "upside" and too protected against "downside," and accordingly, not a partner for federal income tax purposes and ineligible to be allocated millions of dollars of tax credits.

In response to the resulting equity market uncertainty, Revenue Procedure 2014-12 was issued in late December (and revised in early January) providing a "safe harbor," to give taxpayers confidence that their investment won't be challenged.

Get Forrest's column here for more information.