Confidential taxpayer obtains No Action Letter following audit of transaction involving historic new markets and rehabilitation tax credits
Clients Confidential taxpayer
Jones Day successfully represented a confidential taxpayer in the audit of a transaction involving state and federal historic new markets tax credits and federal historic rehabilitation tax credits. Although the transaction closed and the years in question were prior to both the Third Circuit's decision in Historic Boardwalk and the IRS's issuance of Rev. Proc. 2014-12, the Service made inquiries based on both authorities. The matter concluded with the issuance of a no action letter.