New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations.
As previously discussed, the 2017 Tax Cuts...more
3/8/2018
/ Asset Management ,
Business Assets ,
Business Taxes ,
C-Corporation ,
Capital Gains ,
Carried Interest ,
Fund Managers ,
Investors ,
IRS ,
Limited Liability Company (LLC) ,
Partnership Interests ,
S-Corporation ,
Tax Cuts and Jobs Act
The IRS recently issued Notice 2016-31, providing further guidance regarding the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the Internal Revenue Code and the investment tax...more
5/16/2016
/ Biomass ,
Energy Projects ,
Energy Sector ,
Geothermal Energy ,
Hydropower ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Protecting Americans from Tax Hikes (PATH) Act ,
Qualified Energy Facilities ,
Renewable Energy ,
Renewable Energy Incentives ,
Safe Harbors ,
Solar Energy ,
Wind Power
Recently, the Internal Revenue Service issued final regulations addressing reorganizations, commonly referred to as “F reorganizations,” under Section 368(a)(1)(F) of the Internal Revenue Code (the Code). F reorganizations...more
On September 4, 2015, the Internal Revenue Service released a private letter ruling that could have meaningful impacts on the funding and development of certain residential solar developments, specifically community solar...more
The Internal Revenue Service recently issued the expected Notice 2015-25, which supplements its earlier notices on the same subject and provides additional guidance to renewable energy facility developers and investors when...more