Service Issues Safe Harbor Guidance for Allocating Rehabilitation Tax Credits in Light of Third Circuit’s Decision in Historic Boardwalk Hall, LLC

Service Issues Safe Harbor Guidance for Allocating Rehabilitation Tax Credits in Light of Third Circuit’s Decision in Historic Boardwalk Hall, LLC

In Rev. Proc. 2014-12, 2014-3 IRB 1 (12/30/2013), the Internal Revenue Service issued guidance explaining under what set of circumstances it will not challenge a partnership  allocation of  section 47 rehabilitation tax credits to its partners, i.e., the investor partner seeking a full or large allocation of the available credits.