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AUGUST 10, 2016 | Nixon Peabody’s DC Office + Teleseminar
IPED is not offering an audio recorded version of the forum teleseminar for registrants of the program, or for purchase post-teleseminar.



Wednesday, August 10, 2016


1:30 PM Registration
2:00 PM Sessions (teleseminar available)
5:00–6:30 PM Reception


In-Person: Nixon Peabody
799 Ninth Street NW, Suite 500
Washington, DC 20001

Teleseminar: dial-in information provided 24 hours prior to the start of the forum


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April Stephen

The long-anticipated release of IRS Guidance on 50(d) income will significantly affect historic and renewable tax credit transactions that make use of the “lease pass through” or “inverted lease” structure. Join us for this afternoon business forum in Washington, DC, where we will gather industry experts and explore what’s new and what’s next for historic and renewable projects as a result of the new guidance.

You’ll hear the people at the forefront of these changes, including the lead author from the Internal Revenue Service (invited), the Historic Tax Credit Coalition, and renewable energy professionals who were actively involved in the process. They’ll discuss the effects of the guidance on business, and their respective industries and projects. You’ll also hear from active investors and developers who will talk about living with the new rules.

We'll review the main issues that have arisen from the release of the guidance, including:

  • How have the new rules affect whether and when 50(d) income is included in the investor’s basis in its interest. How does this change the expected tax consequences of the transaction?
  • Is the recognition of 50(d) income subject to flips and changes in membership interests at the master tenant level?
  • Is the income accelerated on account of puts, lease modifications, and other significant events? How and when is acceleration reported?
  • How will the new rules and effective dates affect already closed and in-service projects? How will they affect the negotiation of new transactions?

In addition, we’ll walk through examples of different transactions to illustrate both the basic and fine points of the new rules.

Attending this business forum provides you with a chance to connect with business and professional colleagues and explore the changing landscape of the industry. Don’t miss this opportunity for cutting-edge guidance, networking, and open discussions with industry authorities.

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