Paul Handelman of the Office of Chief Counsel released today Chief Counsel Advice (CCA) 201505038.  The CCA makes clear that, in a Master Lease Pass-Through structure, the taxpayer must ratably include related 50(d) income in an amount equal to 100% (rather than 50%) of the rehabilitation tax credit.

The CCA does not, however, address which taxpayer must recognize such income or whether such income inclusion is a partner or partnership tax item.