New Internal Revenue Service temporary regulations provide guidance on the income inclusion rules that apply when a lessor elects to treat a lessee as having acquired investment credit property under Treas. Reg. § 1.48-4. As expected, the new temporary regulations also provide that a partner of a lessee partnership cannot increase its basis in its partnership interest for this income inclusion.
Investment Tax Credit Lessee Income Inclusion Guidance Issued
By Philip Tingle, Chelsea Hess, Gale E. Chan, Heather Cooper and Madeline Chiampou Tully on July 26, 2016
Posted In IRS Guidance, Uncategorized
Philip TinglePhilip (Phil) Tingle represents energy companies such as utilities, independent power producers and financial institutions on a wide range of energy tax-related matters. He is the global head of the Firm's Energy Advisory Practice Group. Phil provides advice regarding all aspects of renewable-energy projects, including tax equity structures, refinancings, acquisitions and dispositions, restructurings and workouts. He has extensive experience with the production tax credit and with the application of renewable credits to new technologies. Moreover, he works with the investment tax credit for numerous kinds of solar projects. Read Philip Tingle's full bio.
Chelsea HessChelsea E. Hess focuses her practice on tax matters. Read Chelsea Hess' full bio.
Gale E. ChanGale E. Chan focuses her practice on federal and international tax matters involving partnerships, limited liability companies and corporations. Gale advises clients on energy tax issues, including advising on renewable energy projects and nuclear energy decommissioning, and state audit examinations involving challenges to complex partnerships and limited liability company structures. Read Gale Chan's full bio.
Heather CooperHeather Cooper works on federal income tax matters, with a focus on energy tax issues. She represents clients in restructurings, mergers and acquisitions, and other transactional energy related matters. Heather's national practice includes advising on all aspects of renewable energy transactions such as solar and wind projects. She provides advice on tax equity structures, refinancings, acquisitions and dispositions, restructurings and workouts. Read Heather Cooper's full bio.
Madeline Chiampou TullyMadeline Chiampou Tully represents clients on federal income tax matters relating to taxable and tax-free mergers, acquisitions and divestitures, corporate restructurings and finance transactions. Within these areas, her tax practice focuses on energy tax issues, including advising on renewable energy transactions such as solar and wind projects. Read Madeline Chiampou Tully's full bio.
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