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Window Widens For Completing Construction On Renewable Energy Projects

Good news came for renewable energy developers on June 29, 2021, when the IRS issued Notice 2021-41. The notice gives developers more time to finish projects and makes it easier to prove that they began construction on a...more

Offshore Wind Projects Receive Boost In Stimulus Bill And New IRS Notice

The rapidly growing offshore wind sector received a significant boost at the end of 2020, thanks to the creation of a new investment tax credit (“ITC”) for offshore wind projects and the issuance of an IRS notice extending...more

Payroll Tax Relief Provisions Of COVID-19 Legislation

In response to the coronavirus pandemic, Congress has passed legislation to encourage continued payment of wages and benefits by providing relief to employers in the form of payroll-related tax credits, loans, and...more

Coronavirus (COVID-19) “CARES Act” Provides Targeted Tax Relief For Businesses

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act, H.R. 748 (the “CARES Act”) was approved by Congress and signed into law by President Trump. The legislation is approximately 880 pages in length and...more

New Section 956 Regulations Expand Scope of the New Participation Exemption But May Expose Borrowers to Increased Collateral...

On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section 956 of the Internal Revenue Code (the “Code”) in an attempt to align it...more

Private Ruling Endorses Taxpayer-Friendly Reading of “Qualified Small Business” Under Section 1202

On September 5, 2014, the Internal Revenue Service (“IRS”) released Private Letter Ruling 201436001 (the “Ruling”), which found that a company providing products and services primarily within the pharmaceutical industry was a...more

Recently Proposed Treasury Regulations Regarding the Allocation of Partnership Recourse and Nonrecourse Liabilities Contain...

On January 29, 2014, the Internal Revenue Service (“IRS”) and the Treasury Department issued proposed regulations (the “Proposed Regulations”) modifying the rules under Section 752 regarding the allocation of recourse and...more

Recent Changes Allow Tax-Free Receipt of up to $10 Million in Gain from the Sale of Small Business Stock

One silver lining to the American Taxpayer Relief Act of 2012 (“ATRA”) is that it extended the 100% exclusion for capital gain on qualified small business stock (“QSBS”) acquired between 2010 and 2011 to include stock...more

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