Joshua Williams

Joshua Williams

Akin Gump Strauss Hauer & Feld LLP

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FATCA — Final Deadline to Obtain a GIIN for Model 1 IGA FFIs

Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more

12/8/2014 - Deadlines FATCA FFI GIIN IRS

IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager

On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more

9/11/2014 - Income Taxes Investment Adviser IRS Self-Employment Tax

Treasury Proposes REIT Solar Regulations but Excludes Most Common Transactions

On the same day as President Obama’s speech championing solar, the Department of the Treasury proposed regulations defining “real estate assets” for purposes of the definition of a real estate investment trust (REIT). The...more

5/13/2014 - Barack Obama MLPs Partnership Agreements Publicly-Traded Companies Real Estate Investments REIT Solar Panels U.S. Treasury

Baucus Post-2016 Proposal: No Change to PTC & ITC Reduced to 20 Percent

Today, the chairman of the Senate Finance Committee, Max Baucus (D-MT), released his proposal for energy tax incentives as part of overall tax reform. The proposal is thoughtful and merits serious consideration by the...more

12/19/2013 - Energy Energy-Efficiency Tax Credits Greenhouse Gas Emissions Investment Tax Credits Master Limited Partnerships Production Tax Credit Renewable Energy Solar Energy Tax Incentives Tax Reform Wind Power

IRS Provides Helpful Clarification to PTC “Start of Construction” Rules

On September 20th, the IRS in Notice 2013-60 clarified three critical issues in its guidance as to whether a wind project (or other type production tax credit (PTC) eligible project) is considered to have “started...more

9/23/2013 - Construction Contracts IRS Production Tax Credit Tax Credits

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