Julie Marion

Julie Marion

Latham & Watkins LLP

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Latest Publications


IRS Issues Additional Guidance on “Begun Construction” Requirement for Wind Energy Credits

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

New Long-Term Extension of Wind and Solar Tax Credits Subject to Phase-out

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

12/22/2015 - Energy Sector Solar Energy Tax Credits Wind Power

New Tax Audit Regime Constitutes a Sea Change for Partnerships

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

11/9/2015 - Audits IRS K-1 Partnerships TEFRA

IRS Proposes Significant Changes to Rules for Allocating Partnership Liabilities

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

2/10/2014 - Indemnification IRS Partnerships Tax Liability

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