Pamela Charles

Pamela Charles

Davis Wright Tremaine LLP

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Additional IRS Guidance on Physical Work Test and Facility Transfers for Energy Tax Credits

The IRS has released additional guidance (Notice 2014-46) on the “beginning of construction” requirement for the renewable energy production tax credit under Code Section 45 (PTC) and energy investment tax credit under Code...more

8/15/2014 - Energy Energy Policy Energy Tax Incentives Investment Tax Credits IRS Production Tax Credit Tax Credits

Are REITs a Viable Strategy for Communications Companies?

Windstream Holdings, Inc. recently announced plans to spin off its copper, fiber and other fixed real estate assets into an independent publicly traded real estate investment trust (REIT). Windstream received a private letter...more

8/12/2014 - Corporate Tax Rates Corporate Taxes IRS Popular Private Letter Rulings REITS Spinoffs Telecommunications Wireless Industry

Additional IRS Guidance on “Beginning of Construction” for ATRA 2012 Tax Credit Extensions

The IRS has released additional guidance (IRS Notice 2013-60) on satisfying the new “beginning of construction” requirement for the renewable energy production tax credit under Code Section 45 (PTC) and energy investment tax...more

9/26/2013 - Construction Contracts Energy Policy Investment Tax Credits IRS ITC Production Tax Credit Renewable Energy Tax Credits

Section 1603 Cash Grant Modified Annual Report Form

Recipients of Section 1603 cash grants are required by the Terms and Conditions of the program to provide annual project performance reports to the Treasury Department for the first five years after the project is placed in...more

5/3/2013 - 1603 Grants U.S. Treasury

IRS Guidance on “Beginning of Construction” for ATRA 2012 Tax Credit Extensions

The IRS has issued guidance (Notice 2013-29) on satisfying the new “beginning of construction” requirement for the renewable energy production tax credit under Code Section 45 (PTC) and energy investment tax credit under Code...more

4/19/2013 - Begun Construction Test Investment Tax Credits IRS Physical Work Test Production Tax Credit Safe Harbors Tax Credits

Qualifying Advanced Energy Project Program: IRS Announces Second Phase

Last month, the IRS announced the second phase of the qualifying advanced energy project program to distribute the Section 48C tax credits that are available for reallocation now that the first phase of the program has been...more

3/21/2013 - DOE IRS Qualified Advanced Energy Projects Tax Credits

Qualifying Advanced Energy Project Program: IRS Announces Second Phase

The IRS has announced the second phase of the qualifying advanced energy project program to distribute the Section 48C tax credits that are available for reallocation now that the first phase of the program has been completed...more

2/11/2013 - DOE Energy-Efficiency Tax Credits Greenhouse Gas Emissions IRS Manufacturers Tax Credits

Production Tax Credit Update: IRS Plans to Release Guidance on Applying the “Begun Construction” Test

According to Tax Notes Today, the IRS discussed its plans to release guidance on applying the “begun construction” test for the production tax credit (“PTC”) at the American Bar Association Section of Taxation meeting in...more

2/5/2013 - American Taxpayer Relief Act Begun Construction Test IRS Production Tax Credit

More Information About the Extension of the Production Tax Credit

The American Taxpayer Relief Act of 2012, which was passed by Congress to avoid the “fiscal cliff,” extends certain federal income tax benefits for renewable energy projects, including...more

1/4/2013 - American Taxpayer Relief Act Fiscal Cliff Investment Tax Credits Production Tax Credit Renewable Energy Wind Power

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