Within BakerHostetler’s Tax Controversy and Litigation practice, we have attorneys with specific experience representing clients whose tax credit transaction is being challenged by the Internal Revenue Service (IRS).
Our firm’s thorough understanding of the technical requirements for the various tax credits (specifically NMTCs, HTCs, and LIHTCs), combined with our experience with all stages of an IRS challenge (e.g., administrative audit, appeals, post-appeals mediation and litigation) and our attorneys’ backgrounds, which include attorneys formerly with the IRS, U.S. Department of Justice, U.S. Tax Court and U.S. Department of the Treasury, provide our clients with a significant competitive edge when responding to a challenge brought by the IRS centering around a tax credit.
Our tax credit controversy experience includes representing clients with respect to satisfaction of “qualified rehabilitation expenditure” and other regulatory requirements, HTC pass-through elections, tax-exempt use, interaction with easement donations, and partnership issues, including Historic Boardwalk based challenges.