In what some might view as a Holiday surprise, the IRS and Treasury today released a safe harbor revenue procedure for a partnership’s allocation of historic rehabilitation tax credits. While on its face the guidance is limited to the housing rehabilitation credit, in the absence of other guidance, it should provide important insights into the
Kurt Baca is a member of the firm’s Tax group. His practice focuses on the federal income taxation of domestic and international financing transactions and financial instruments, including issues arising from investment and trading programs involving foreign currencies, debt instruments, equities, derivatives and other financial instruments.
Mr. Baca has substantial experience advising investment banks and Fortune 100 companies in structuring and implementing such finance and investment transactions, including the issues of corporate and partnership taxation that relate to those transactions.
He has also represented issuers and underwriters in the development and execution of high profile capital market transactions, including various forms of convertible debt and structured investment units. Mr. Baca has significant experience in advising clients in audits and controversies arising from corporate financing transactions.