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Tax Law Roundup current law developments in U.S. taxation

Tag Archives: credits

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

Posted in International, Partnership/LLC, Tax Credits

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs.  The regulations are effective on February 4, 2016. The existing regulations provide special rules for foreign tax expense allocations when those expenses are eligible for… Continue Reading

Senate Passes Extenders Legislation For Calendar Year 2014

Posted in General, Legislative

In the annual ritual of last minute legislative action, the Senate has passed the renewal of nearly all of the so-called Extenders legislation by a vote of 76 to 16, which will make the tax incentives applicable to calendar year 2014 if signed by the President.  As is all too common, the Tax Increase Prevention… Continue Reading

Third Circuit Concludes Historic Rehab Credit Investors Were Not Partners

Posted in Debt vs. Equity, Economic Substance, Partnership/LLC, Real Estate, Tax Credits

The IRS has won a significant victory in the world of tax credit partnerships.  Federal tax credits are typically monetized through syndicated credit-investment partnerships where the investor is required to be treated as a partner for tax purposes in order to receive an allocation of the credit.  In a reversal of the Tax Court, the… Continue Reading