On May 16, 2024, the Internal Revenue Service (IRS) published Notice 2024-41 (Notice), which modifies Notice 2023-38 (Prior Notice) by providing a new elective safe harbor (Safe Harbor) that will allow taxpayers to use...more
The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more
6/16/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Energy Market ,
Energy Sector ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Proposed Regulation ,
Proposed Rules ,
Tax Credits ,
Tax Planning ,
Webinars
The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more
In Private Letter Ruling 201946007, the Internal Revenue Service (IRS) allowed a tax equity investor to participate with a regulated utility in a tax equity financing arrangement for wind investments without being subject to...more
12/3/2019
/ Energy Sector ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Popular ,
Private Letter Rulings ,
Production Tax Credit ,
Public Utilities Commission ,
Renewable Energy ,
Revenue Procedures ,
Safe Harbors ,
Tax Equity Partnership
On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party...more
6/27/2019
/ 1603 Grants ,
Burden of Persuasion ,
Burden of Proof ,
Energy Sector ,
Evidence ,
Fees ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Land Developers ,
Renewable Energy ,
Tax Credits ,
Wind Farm
The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more
New Internal Revenue Service (IRS) temporary regulations provide guidance on the income inclusion rules that apply when a lessor elects to treat a lessee as having acquired investment credit property under Treas. Reg. §...more
As discussed in our post on April 7, US Congress extended the Production Tax Credit (PTC) under Internal Revenue Code (IRC) Section 45 and the Investment Tax Credit (ITC) under IRC Section 48 in December 2015, but failed to...more
As discussed in our post on March 16, the Congressional extension of the Production Tax Credit (PTC) under Internal Revenue Code (IRC) Section 45 and the Investment Tax Credit (ITC) under IRC Section 48 in December 2015...more
Renewable Energy Industry Seeks Additional Energy Credit Clarifications -
On December 18, 2015, President Barack Obama signed into law the Consolidated Appropriations Act, 2016 (H.R. 2029) (the Act). The Act includes...more
On December 18, 2013, Senate Finance Committee Chairman Max Baucus (D-MT) released a proposal that would streamline energy tax incentives to make them more predictable and technology neutral. The proposal would consolidate...more
2/7/2014
/ Carbon Capture and Sequestration ,
Clean Energy ,
Coal ,
Energy Sector ,
Energy Tax Incentives ,
Environmental Protection Agency (EPA) ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
Nuclear Power ,
Production Tax Credit ,
Tax Reform ,
Utilities Sector ,
Wind Power