Madeline Chiampou Tully
Subscribe to Madeline Chiampou Tully's PostsMadeline 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.
Ready or Not, Here They Come! The New Partnership Audit Rules
By Kevin Spencer, Kristen E. Hazel and Madeline Chiampou Tully on Dec 27, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
On November 2, 2015, the Bipartisan Budget Act of 2015, (the Act), H.R. 1314, 114 Congress/Public Law No. 114-74, made significant changes to the rules governing US federal income tax audits of partnerships (New Audit Rules). The New Audit Rules are codified at Internal Revenue Code Sections 6221 through 6241. On August 4, 2016, the...
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Investment Tax Credit Lessee Income Inclusion Guidance Issued
By Chelsea Hess, Gale E. Chan, Heather Cooper, Madeline Chiampou Tully and Philip Tingle on Jul 26, 2016
Posted In IRS Guidance, Uncategorized
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...
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IRS Revises Recent Begin Construction Guidance
By Philip Tingle, Gale E. Chan, Heather Cooper, Kevin Spencer and Madeline Chiampou Tully on May 20, 2016
Posted In IRS Guidance, Uncategorized
On May 18, 2016, the Internal Revenue Service (IRS) revised Notice 2016-31 (Notice), its recent guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass, geothermal, landfill gas, trash, hydropower, and marine and hydrokinetic facilities). For a discussion of the Notice, click here. The revisions clarify that the Continuity...
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New Issue of ‘Focus on Tax Strategies and Developments’
By McDermott Will & Emery, Gary C. Karch, Kevin Spencer, Madeline Chiampou Tully, Michael J. Wilder and Robbie H. R. Chen on May 12, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
We recently released the May 2016 issue of “Focus on Tax Strategies and Developments,” which can be viewed in its entirety here or through the links below. The issue includes four articles of interest to taxpayers: Proposed Debt-Equity Regulations Have Dramatic Implications for Corporate Tax Planning and Compliance By Thomas W. Giegerich and Michael J. Wilder On...
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IRS Issues Guidance on the Beginning of Construction Rules for Renewable Projects
By Gale E. Chan, Heather Cooper, Kevin Spencer, Madeline Chiampou Tully and Philip Tingle on May 11, 2016
Posted In IRS Guidance, Uncategorized
The Internal Revenue Service recently issued Notice 2016-31, which provides much-needed guidance for wind and other qualified facilities on meeting the beginning of construction requirements in light of the 2015 statutory extension and modification of the production tax credit and the investment tax credit. The Notice also revises and adds to the list of excusable...
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IRS Determines Refined Coal Transaction Doesn’t Have Economic Substance
By Kevin Spencer, Madeline Chiampou Tully and Philip Tingle on Mar 24, 2016
Posted In IRS Guidance, Uncategorized
On March 17, 2016, the Internal Revenue Service (IRS) issued a Field Attorney Advice Memorandum, 20161101F (Dec. 3, 2015) (the FAA). In the FAA, the IRS concluded that an investment in a partnership designed to deliver a tax credit allocation did not have a potential for profit or risk of loss, was not a meaningful...
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