IRS Clarifies Income Inclusion Amount Under Section 50(d)(5)

Monday, February 2, 2015 - 8:00AM

The Internal Revenue Service (IRS) last week issued Chief Counsel Advice Memorandum 201505038, which addresses the amount of additional income required to be recognized by a lessee in a historic tax credit (HTC) transaction using a lease pass-through structure. The memorandum states that the additional income, often known as 50(d) income, is 100 percent of the credit allowable. There had been some question as to whether 50(d) income is based on 50 percent or 100 percent of the allowable credit.


Tune into the Feb. 3 episode of the Tax Credit Tuesday podcast for more information.

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