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IRS issues long-awaited guidance regarding the allocation of federal rehabilitation tax credits

USA - January 1 2014 The Internal Revenue Service ("IRS") recently issued guidance in Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47...

J. Conrad Garcia, Craig L. Rascoe, Allison T. Domson, J. Patrick Becker.

Tax Court ruling impacts the treatment of income allocations attributable to unvested partnership capital interests

USA - December 6 2013 The United States Tax Court recently issued its opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15 (12213), a ruling regarding...

J. Conrad Garcia, J. Patrick Becker.

The “meaningful stake” debate: Third Circuit reverses Tax Court decision in historic boardwalk

USA - August 31 2012 On August 27, 2012, the United States Court of Appeals for the Third Circuit reversed the holding of the United States Tax Court in the case of Historic Boardwalk Hall, LLC v. Commissioner, 136 T.C. 1 (2011)....

J. Conrad Garcia, Allison T. Domson.

Characterizing and quantifying reasonable compensation of S corporation

USA - March 2 2012 The Eighth Circuit recently issued its decision in the case of David E. Watson, P.C. v. U.S., No. 11-1589 (8th Cir. 22112), which dealt with the issue of determining reasonable compensation in a closely held S corporation for FICA tax purposes....

J. Conrad Garcia.

Aircraft acquisitions: eligibility for bonus depreciation in 2010, 2011

USA - October 28 2010 President Obama signed the Small Business Jobs Act of 2010 (the "Act") into law on Sept....

Judy Lin Bristow.