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The Trump Freeze Leaves New Proposed Regulations on Partnership Audit Rules out in the Cold

A White House freeze on recently issued regulations has left proposed regulations on the new Centralized Partnership Audit Regime out in the cold. On January 20, 2017, a memorandum from Assistant to the President and Chief...more

Treasury Guidance Clarifies and (Again) Expands Field of Renewable Energy Projects That May Qualify for the PTC or ITC

Notice 2017-04, issued on December 15, 2016, clarifies and expands the beginning of construction and continuity safe harbors applicable to certain alternative energy projects, including wind installations. Like Notice...more

New Temporary Regulations Deny Basis Increase in Partnership Interests in Lease Passthrough ITC Structures

On July 21, the U.S. Treasury Department (“Treasury”) released temporary and proposed regulations denying a basis increase to equity holders of lessee partnerships and S corporations to account for mandatory income inclusions...more

New Treasury Guidance Significantly Expands Field of Renewable Energy Projects That May Qualify for the PTC or ITC

On May 5, the U.S. Treasury Department released Notice 2016-31 to address certain changes made to the Production Tax Credit (“PTC”) and Investment Tax Credit (“ITC”) in the Protecting Americans from Tax Hikes (“PATH”) Act of...more

Tax Exclusions for Sale of Stock Issued by Qualified Small Business Corporations Becomes Permanent — At Least Temporarily

Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more

PATH Act Presents Opportunities for Tax-Efficient Non-U.S. Investment in U.S. Real Estate

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among its numerous revisions to federal tax law, the PATH Act significantly amended various...more

A New Model for Clean Energy: Community Solar Gardens

Declining prices for solar equipment and generous government incentives have broadened the appeal of community solar gardens. Community solar gardens, which are arrangements in which multiple users invest in and benefit from...more

New Tax Guidance Would Simplify Rules for Shareholders of Institutional Money Market Funds

On July 23, 2014, the Securities and Exchange Commission (SEC) adopted final rules governing the structure and operation of money market funds (SEC MMF Reform Rules). See our client alert entitled “SEC Adopts Floating-NAV and...more

New Guidance on Historical Rehabilitation Credits May Indicate Tougher Safe Harbors for Other Investment Tax Credits in the Future

On December 30, 2013, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2014-12, which sets out a new “safe harbor” for allocations of the historical rehabilitation credit (the “HRC”) among partners in a...more

IRS Notice 2013-60 Clarifies Rules on Beginning of Construction

On September 20, 2013, the U.S. Department of the Treasury (“Treasury”) released Notice 2013-60, which clarifies in important ways the eligibility rules applicable to the investment tax credit (“ITC”) and production tax...more

Ninth Circuit Decision Creates New Tax Opportunities and Challenges in Indian Country

Since the Supreme Court’s 1973 decision in Mescalero Apache Tribe v. Jones, it has been clear that state and local tax authorities could not assess property tax on permanent improvements located on tribal trust land when...more

Exclusion from Tax for Stock Issued by Qualified Small Business Corporations

On November 3, 2010 and January 18, 2011, we issued client alerts discussing the opportunities provided by the Section 1202 exclusion from tax on gain realized on the sale of certain stock issued by a “qualified small...more

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