On May 16, 2024, the Internal Revenue Service (IRS) published Notice 2024-41 (Notice), which modifies Notice 2023-38 (Prior Notice) by providing a new elective safe harbor (Safe Harbor) that will allow taxpayers to use...more
On August 22, 2022, US President Joe Biden signed the Inflation Reduction Act of 2022 (the Act) into law, which includes $369 billion in energy and climate spending with an unprecedented focus on clean hydrogen. Specifically,...more
On July 27, 2022, Senate Majority Leader Chuck Schumer (D-NY) and Senator and Energy and Natural Resources Chair Joe Manchin (D-WV) announced an agreement on a proposed reconciliation package called the Inflation Reduction...more
The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more
6/16/2020
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Carbon Emissions ,
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Income Taxes ,
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The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more
6/9/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Energy Market ,
Energy Sector ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Proposed Regulation ,
Proposed Rules ,
Tax Credits ,
Tax Planning ,
Webinars
The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more
In Private Letter Ruling 201946007, the Internal Revenue Service (IRS) allowed a tax equity investor to participate with a regulated utility in a tax equity financing arrangement for wind investments without being subject to...more
12/3/2019
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Production Tax Credit ,
Public Utilities Commission ,
Renewable Energy ,
Revenue Procedures ,
Safe Harbors ,
Tax Equity Partnership
On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party...more
6/27/2019
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Burden of Persuasion ,
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Energy Sector ,
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Income Taxes ,
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Renewable Energy ,
Tax Credits ,
Wind Farm
New Internal Revenue Service (IRS) temporary regulations provide guidance on the income inclusion rules that apply when a lessor elects to treat a lessee as having acquired investment credit property under Treas. Reg. §...more
As discussed in our post on April 7, US Congress extended the Production Tax Credit (PTC) under Internal Revenue Code (IRC) Section 45 and the Investment Tax Credit (ITC) under IRC Section 48 in December 2015, but failed to...more
In Depth -
On June 10, 2016, the Internal Revenue Service (IRS) issued Notice 2016-36 (the Notice), updating the safe harbor (Safe Harbor) regarding transfers of property from an electricity generator to a regulated...more
As discussed in our post on March 16, the Congressional extension of the Production Tax Credit (PTC) under Internal Revenue Code (IRC) Section 45 and the Investment Tax Credit (ITC) under IRC Section 48 in December 2015...more
Renewable Energy Industry Seeks Additional Energy Credit Clarifications -
On December 18, 2015, President Barack Obama signed into law the Consolidated Appropriations Act, 2016 (H.R. 2029) (the Act). The Act includes...more