Gregory Broome

Wilson Sonsini Goodrich & Rosati

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Federal Circuit Reverses and Remands Alta Wind Case Holding that a Portion of the Asserted Section 1603 Basis May be Allocable to...

In a case decided on July 27, 2018, the U.S. Court of Appeals for the Federal Circuit (the Court of Appeals) reversed the Court of Federal Claims' (the Claims Court) decision in Alta Wind I Owner-Lessor C et al v. United...more

8/1/2018 / 1603 Grants , Acquisitions , Alta Wind Energy Center , American Recovery and Reinvestment Act , Energy Sector , Power Purchase Agreements , Remand , Renewable Energy , Tangible Property , Wind Farm

IRS Issues Notice 2018-59: "Begun Construction" Guidance for the Investment Tax Credit

On June 22, 2018, the IRS issued Notice 2018-59 (ITC Guidance), providing long-awaited guidance on the "begun construction" requirements for facilities qualifying for the Section 48 investment tax credit (ITC). The ITC is a...more

6/26/2018 / Begun Construction Test , Energy Projects , Investment Tax Credits , IRS , New Guidance , Physical Work Test , Production Tax Credit , Renewable Energy , Safe Harbors

IRS Issues Notice Clarifying Earlier Guidance on "Beginning of Construction" Requirement for PTC and ITC Purposes

On September 20, 2013, the IRS released Notice 2013-60, which clarified Notice 2013-29. Each Notice addresses the requirement that construction of a qualified facility must begin before January 1, 2014, in order to be...more

9/25/2013 / Construction Contracts , Investment Tax Credits , IRS , Production Tax Credit , Renewable Energy , Tax Credits

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