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
Lee Kelley is of counsel in the Tax Practice Group. Her practice focuses on structuring domestic and cross-border acquisitions and dispositions, post-acquisition integration transactions, and internal group restructurings for both domestic and foreign- parented multinational corporations. Ms. Kelley also frequently advises companies with respect to the tax consequences of debt restructurings, the classification of financial instruments as debt or equity, and the applicability of section 382 to loss corporations.
Ms. Kelley is one of a only a handful of tax lawyers who has held executive posts at both the Internal Revenue Service and the U.S. Department of Treasury. At Treasury, she served as Deputy Tax Legislative Counsel where she participated in the development of legislation, regulations and administrative guidance concerning corporations and their shareholders, partnerships, and exempt organizations. At the I.R.S., Ms. Kelley served as the Deputy Associate Chief Counsel for Corporate Taxation. In that capacity, she managed the issuance of private letter rulings to corporations and their shareholders, and participated in the development of the government's positions in matters of tax controversy.
Prior to Ms. Kelley's role at Treasury, she was associated with the national offices of two public accounting firms. Ms. Kelley is a frequent public speaker on matters relating to taxation.