Gale E. Chan
Subscribe to Gale E. Chan's PostsGale E. Chan focuses her practice on federal and international tax matters involving partnerships, limited liability companies and corporations. Gale advises clients on energy tax issues, including advising on renewable energy projects and nuclear energy decommissioning, and state audit examinations involving challenges to complex partnerships and limited liability company structures. Read Gale Chan's full bio.
Tax Court Holds Payment from Qualified Settlement Fund is Includable in Taxpayer’s Gross Income
By Gale E. Chan on Sep 25, 2017
Posted In Court Procedure Matters, Trial Courts, Uncategorized
In Ritter v. Commissioner, TC Memo. 2017-185 (September 19, 2017), the Tax Court held that a taxpayer’s receipt of a payment from a section 468B qualified settlement fund (QSF) was includable in gross income for the 2013 taxable year. The QSF was established pursuant to a settlement agreement between a federal banking regulator and the...
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Analysis of Energy and Tax Proposals in the 2018 Budget Proposal
By Gale E. Chan, Heather Cooper and Philip Tingle on May 26, 2017
Posted In Tax Refunds, Uncategorized
President Trump released his budget proposal for the 2018 FY on May 23, 2017, expanding on the budget blueprint he released in March. The budget proposal and blueprint reiterate the President’s tax reform proposals to lower the business tax rate and to eliminate special interest tax breaks. They also provide for significant changes in energy...
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Investment Tax Credit Lessee Income Inclusion Guidance Issued
By Chelsea Hess, Gale E. Chan, Heather Cooper, Madeline Chiampou Tully and Philip Tingle on Jul 26, 2016
Posted In IRS Guidance, Uncategorized
New Internal Revenue Service temporary regulations provide guidance on the income inclusion rules that apply when a lessor elects to treat a lessee as having acquired investment credit property under Treas. Reg. § 1.48-4. As expected, the new temporary regulations also provide that a partner of a lessee partnership cannot increase its basis in its...
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Do Partnerships Now Need to Reserve for Taxes?
By Gale E. Chan and Kevin Spencer on Jun 6, 2016
Posted In Uncategorized
The Bipartisan Budget Act of 2015, P.L. 114-74, added new partnership audit rules, which are generally effective for tax years beginning in 2018. These new rules will allow the Internal Revenue Service (IRS) to assess and collect tax due on partnership adjustments at the entity level. Some partnerships will be able to elect out of...
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IRS Revises Recent Begin Construction Guidance
By Gale E. Chan, Heather Cooper, Kevin Spencer, Madeline Chiampou Tully and Philip Tingle on May 20, 2016
Posted In IRS Guidance, Uncategorized
On May 18, 2016, the Internal Revenue Service (IRS) revised Notice 2016-31 (Notice), its recent guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass, geothermal, landfill gas, trash, hydropower, and marine and hydrokinetic facilities). For a discussion of the Notice, click here. The revisions clarify that the Continuity...
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IRS Issues Guidance on the Beginning of Construction Rules for Renewable Projects
By Gale E. Chan, Heather Cooper, Kevin Spencer, Madeline Chiampou Tully and Philip Tingle on May 11, 2016
Posted In IRS Guidance, Uncategorized
The Internal Revenue Service recently issued Notice 2016-31, which provides much-needed guidance for wind and other qualified facilities on meeting the beginning of construction requirements in light of the 2015 statutory extension and modification of the production tax credit and the investment tax credit. The Notice also revises and adds to the list of excusable...
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