Treasury finalizes rules for key component of tax reform for pass-through trades and businesses.
Key Points:
..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more
Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partner’s effectively connected gains or losses from a transfer of its interest in a partnership engaged in a US trade or...more
Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs.
Key Points:
..Investors in qualified opportunity funds may derive significant tax benefits in the...more
11/7/2018
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Deferral ,
U.S. Treasury
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Major tax overhaul will reshape the renewables and energy industries.
Key Points:
..Sponsors must navigate new tax rules in search of lowest after-tax capital structures.
..A new cross-border tax threatens to...more
Bold proposal seeks changes to tax credits, depreciation, and corporate tax rates.
Key Points:
- Production Tax Credits are cut by more than one-third.
- Bill may impact existing and future tax equity...more
New rules provide wind developers with additional time to satisfy a critical safe harbor.
On December 15, 2016, the Internal Revenue Service (IRS) issued Notice 2017-4, which modifies the “continuity safe harbor” as set...more
Favorable decision clarifies the value of cash grants and investment tax credits for renewable energy projects.
A large wind developer won a significant victory in the Court of Federal Claims on October 28 in a case that...more
New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions.
On October 4, 2016, the Internal Revenue Service (IRS)...more
Latest guidance extends “continuity safe harbor” to four years and includes other taxpayer-friendly modifications and clarifications to existing guidance.
On May 5, 2016, the Internal Revenue Service (IRS) issued...more
5/11/2016
/ Begun Construction Test ,
Bipartisan Budget ,
Energy Projects ,
Energy Sector ,
Investment Tax Credits ,
IRS ,
New Guidance ,
Physical Work Test ,
Popular ,
Production Tax Credit ,
Renewable Energy ,
Safe Harbors ,
Wind Power
Congress extends tax credits for wind and solar energy projects, but will phase the credits out over several years.
The Consolidated Appropriations Act, 2016 (the Act), which President Obama signed into law on December...more
Legislation impacts tiered partnerships and M&A transactions. Existing partnerships should review operating agreements before new rules take effect.
The Bipartisan Budget Act of 2015 (the Act), which President Obama...more
Proposed Regulations seek to curtail perceived abuses, including the use of “bottom-dollar” guarantees and some indemnity arrangements.
On January 29, 2014, the Internal Revenue Service (IRS) proposed regulations that...more