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IRS issues final regulations on section 468A nuclear decommissioning costs

On September 3, 2020, the Internal Revenue Service (IRS) released long-awaited final regulations (Final Regulations) under section 468A of the Internal Revenue Code of 1986, as amended (Code). The Final Regulations generally...more

Spreading like wildfires - The IRS addresses an atypical “government grant” under IRC Sec. 197

In the wake of the devastating wildfires that engulfed the State of California in 2019, California enacted legislation, California Assembly Bill 1054, to, amongst other things, authorize the creation of a Wildfire Fund. The...more

IRS reaffirms stance on public utility property for wind energy facility, but again declines to address I.R.C. Sec. 707(b) issue

In PLR 202020011, the Internal Revenue Service (IRS) reaffirmed that a wind energy facility owned by a utility affiliate and unrelated investor in a LLC taxable as a partnership was not “public utility property” because the...more

Normalization ruling covers new ground on supplemental rate proceedings and depreciation-related section 481 adjustments 

On March 6, 2020, the Internal Revenue Service (IRS) released PLR 202010002, which provided the appropriate normalization treatment of infrastructure surcharges in supplemental rate proceedings as well as the proper...more

IRS rules no violation of normalization requirements in computation of pro rata portion of ADIT used to reduce rate base

In a recent private letter ruling (PLR 201949006), the Internal Revenue Service (IRS) addressed the computation of the pro rata portion of accumulated deferred federal income tax reserve (ADFIT, together with the total...more

Ready, fire, aim - IRS Chief Counsel Advisory misses the mark in NOL carryforward position that controvenes the TCJA

In CCA 201928014 (July 12, 2019), the IRS Office of Chief Counsel provides its view of the interplay between the net operating loss (NOL) carryover rules set forth in Internal Revenue Code (Code) § 172(b)(2) and the...more

IRS releases 2019 section 45 production tax credit amounts

The Internal Revenue Service (IRS) recently published a notice providing the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy production tax credits under Internal Revenue...more

IRS requests comments on the normalization requirements relating to excess tax reserves resulting from the Tax Cuts and Jobs Act

On May 7, 2019, the Internal Revenue Service (IRS) released Notice 2019-33 (Notice) announcing its intention to issue guidance under section 168 of the Internal Revenue Code to clarify the normalization requirements for...more

IRS requests comments on section 45Q carbon sequestration credit in Notice 2019-32

On May 2, 2019, the Internal Revenue Service (IRS) released Notice 2019-32 (Notice) requesting comments on anticipated regulations and other guidance under section 45Q of the Internal Revenue Code. Section 45Q was originally...more

Proposed 163(j) regulations provide needed guidance to utilities

On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more

What you need to know about investing in opportunity zones

As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities designated as “Opportunity Zones.”...more

Proposed 168(k) regulations offer several surprises for utilities and present challenges with uncertainties left unaddressed

The proposed regulations under section 168(k) issued by Treasury and the Internal Revenue Service (IRS) on August 3, 2018, not only presented utilities with some surprises, but also raised concerns as a result of unaddressed...more

IRS rules that a method of reflecting a federal income tax settlement in ratemaking violated the consistency rule of normalization

In PLR 201828010, the Internal Revenue Service (IRS) considered the proper ratemaking treatment for reflecting the results of a federal income tax settlement. The taxpayer was a member of an affiliated group filing...more

IRS releases 2018 section 45 production tax credit amounts

The Internal Revenue Service (IRS) recently published Revenue Procedure 2018-50, which provides the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy production tax credits...more

IRS Updates Beginning of Construction Guidance for Renewable Energy Tax Credits Extended by PATH Act

On May 5, 2016, the Internal Revenue Service (IRS) issued Notice 2016-31, which updates prior guidance regarding the beginning of construction requirement for IRC sections 45 and 48 renewable energy tax credits following...more

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