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Guidance On IRS Section 50(d) Income Regulations

Webinar: ID# 1023620
Recorded CD
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About This Course:
The Treasury Department's new regulations under Section 50(d)(5) of the Internal Revenue Code imposed significant changes to the amount and timing of income to parties arising as a result of an election to pass federal rehabilitation or renewable energy credits to a lessee under Section 50(d)(5) of the Code.

Understanding the changes arising from the new Section 50(d)(5) regulations is critical to effectively plan and structure projects that seek to realize rehabilitation or renewable energy credit incentives.

This webinar will help practitioners and developers understand the new Section 50(d)(5) regulations. Get up-to-date on the new rules regarding the allocation and recognition of income, resulting from an election to pass federal rehabilitation or renewable energy credits to a lessee.

AGENDA

Overview of Lease Pass-Through Election Under Section 50(d)(5)
  • Section 47 Rehabilitation Tax Credits
  • Section 48 Renewable Energy Tax Credits
  • Lessor Basis and Lessee Income Effect of Section 50(d) Election
  • Section 47 Rehabilitation Tax Credits
  • Section 48 Renewable Energy Tax Credits
  • What Is 50(d) Income?
  • What Is the Origin of the New Regulations?
Final and Temporary Regulations on Income Inclusion Under Section 50(d)(5)
  • Date of Application of New Regulations
  • What Are Temporary Regs and Proposed Regs?
  • Comments Submitted to the IRS and Status of Responses
  • Errors and Corrections
  • Section 50(d) Income Not a Partnership or S-Corporation Income Item
  • New 'Ultimate Credit Claimant' Definition
  • Section 50(d) Income Impact to Ultimate Credit Claimant
  • Section 47 Rehabilitation Tax Credits
  • Section 48 Renewable Energy Tax Credits
  • Income Impact to Ultimate Credit Claimant in the Event of Recapture Event
  • Section 47 Rehabilitation Tax Credits
  • Section 48 Renewable Energy Tax Credits
  • Timing of Income Inclusion
  • Election to Accelerate 50(d) Income in Event of Lease Termination or Disposition of Interest in Lessee Partnership or S Corporation
  • Timing to Make Election
  • Requirements to Make Election
  • Section 47 Rehabilitation Tax Credits
  • Section 48 Renewable Energy Tax Credits
Discussion of Impact of Regulations on Common Rehabilitation and Renewable Energy Project Structures
  • Consideration of the September 19, 2016 Effective Date - What Is the Impact to Pre- and Post September 19 Transactions?
  • Impact to Direct Structures
  • Impact to Lease Pass-Through Structures
About The Presenters

Joel Cohn, CPA
  • Partner in the Transaction Consulting Group of CohnReznick LLP
  • Since 1995 he has provided transaction structuring advice and technical financial modeling services to sponsors of various tax credit projects including, among others, renewable energy projects
  • His broad experience in raising tax equity brings to bear solutions where business goals and tax rules would appear to conflict; the key is having an understanding of the goals of the various stakeholders, and the alternative ways those goals can be achieved
  • His advice has included maximization of credits through re-categorization of costs, contract restructuring and tax planning, all while working within the framework of tax law; creation of transaction structures designed to satisfy the key agendas of various stakeholders; exit strategy development for investors/ developers - including the creation of various option strategies; development of strategies which maximize sponsor return on investment; and creation of transaction structures that permit economic participation by nonprofits
  • Tax credit transaction experience has included several hundred projects throughout the country, including solar, wind, biomass and hydropower technologies; he has also contributed policy advice to working groups across the country, advising on both federal and state tax credit law, consequently generating substantial improvements to the programs and to the public’s understanding of the law
  • M.B.A., concentration in finance, Loyola University; B.S. degree in business administration, Towson University
David S. Lionberger
  • Partner in Hirschler Fleischer’s business section, heading the tax credit tax and state and local tax groups and co-chairing the taxation section at the firm
  • Specific areas of his practice include representation of owner/developer, investor and financing clients in tax planning and transactions for real estate projects, including a specialty in historic, low-income, new market and conservation credit transactions, as well as property developments, mergers and acquisition planning
  • Represents clients ranging from family and closely-held growth and middle market companies to regional and multi-national businesses, focusing on privately-held companies
  • Examples of matters he’s recently handled include representation of clients before federal, state and local taxing authorities with respect to credit allocations and project structures, assistance to clients to secure historic, new market and low-income housing tax credits and preparation of partnership documents for owner/developers, investors and financing companies participating in credit projects; planning and structuring numerous property development partnerships and financings; negotiation and preparation of numerous conservation easements and conservation donations qualifying for conservation charitable deductions and tax credits, negotiation and closing of multiple sales and acquisitions of middle-market sized businesses; and counseling and preparation of estate and succession plans for closely-held businesses and family assets
  • Member of the American Bar Association, Virginia State Bar and Virginia Bar Association, Tennessee Bar Association and the Richmond Bar Association
  • Has been selected for inclusion as a “Super Lawyer,” Tax, Virginia Super Lawyers, Thomson Reuters, 2012 to 2015, named as "Legal Elite" (Taxes/Estates/Trusts/Elder Law), Virginia Business, 2007 to 2008, 2010 to 2011, 2013 to 2015, and was selected for inclusion as a “Rising Star,” Virginia Super Lawyers, Thomson Reuters, 2007 to 2008
  • J.D. degree, cum laude, Washington & Lee University; LL.M. degree in Taxation, New York University; B.A. degree, University of Virginia
Marshall Phillips
  • Principal in CohnReznick LLP’s Charlotte office
  • Over two decades of experience in finance and accounting with a focus on sourcing equity and debt capital for real estate transactions and has completed numerous engagements for operating companies
  • Works with clients to structure real estate transactions that include the use of the federal and state historic tax credit (HTC) programs, the Low Income Housing Tax Credit (LIHTC), solar/renewable energy investment tax credits (ITC) and incentives, and the federal New Markets Tax Credit (NMTC) Program
  • Expertise includes working, sometimes simultaneously, with the tax equity investors, real estate developers, tax credit syndicators, and regulatory agencies to provide his clients with financially feasible and sound deals
  • Client base includes affordable housing developers, CDEs, governmental entities, commercial real estate developers, housing authorities, and Fortune 100 financial service corporations; he also works with a variety of state credit programs and oversees due diligence on behalf of tax credit investors and tax credit syndicators
  • B.A. degree in economics, Rollins College; M.B.A. degree in finance, Georgia Sate University
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