id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-337	Giegerich, Thomas W	The Monetization of Business Tax Credits	2022	117	.pdf	application/pdf	52826	2636	56	CONCLUSION ................................................................................. 742 I. INTRODUCTION Within the last year or so, two cases have been handed down addressing partnership allocations of tax credits. Many states allow for outright transfers of state tax credits (with associated, if somewhat muddled, federal tax consequences), but Virginia is not among them, and the question before the court was whether the substance of the transaction entered into by the Virginia state tax credit investors, the partnership and the project developer was — under the section 707 3 disguised sale rules or otherwise — a sale of tax credits, notwithstanding the facial impossibility of such a sale in light of the fact that the state tax credits at issue were by the terms of the enabling legislation “nontransferable.”	cache/ftr-337.pdf	txt/ftr-337.txt