Business Organization Tax Energy & Utilities

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Renewable Energy Tax Credits: Recent IRS Notice Favorable to the Renewable Energy Industry

On May 5, 2016, the IRS released new guidance regarding the renewable energy production tax credit (“PTC”) and energy investment tax credit (“ITC”) which most in the renewable energy industry will find favorable....more

Renewable Energy Tax Credits: Recent IRS Notice Favorable to the Renewable Energy Industry

On May 5, 2016, the IRS released new guidance regarding the renewable energy production tax credit (“PTC”) and energy investment tax credit (“ITC”) which most in the renewable energy industry will find favorable. ...more

Doing business inside the UAE’s freezones

If you are considering establishing a business in the UAE, you would be wise to spend time investigating the various idiosyncrasies of the local market. One of the first decisions you will arrive at is where to base your...more

IRS Issues Guidance on Beginning of Construction Rules for Renewable Projects

On May 5, 2016, the Internal Revenue Service (IRS) issued Notice 2016-31, providing guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass, geothermal,...more

Energy Tax Law Alert: IRS Rules That Payment for Intertie Constitutes Taxable Contribution in Aid of Construction

The IRS has issued a private letter ruling concluding that the reimbursement by a solar electric generator of an electric distribution company’s costs to construct an intertie is a contribution in aid of construction under...more

Key Developments in The Photovoltaic Sector in Italy

In Depth - In 2015, solar photovoltaic (PV) systems in Italy generated 24,676 GWh of electricity, representing 9.1 per cent of Italy’s domestic electricity production and 7.8 per cent of the country’s overall...more

After Extension, IRS Clarifies "Begun Construction" Guidance for PTCs

Following last year's extension of the investment tax credit for qualifying projects for which construction begins prior to January 1, 2020, and of the production tax credit (PTC) with respect to certain facilities the...more

Energy Tax Law Alert: IRS Updates "Beginning of Construction" Guidance

The IRS has issued highly anticipated guidance updating the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the Internal Revenue Code (the Code) and the investment tax credit...more

UK Budget 2016: Oil and Gas Taxation

Against the backdrop of higher development costs for aging oil and gas fields, depressed global oil prices and projections of slower global economic growth, the UK government announced significant tax cuts in its Budget 2016...more

Question and Answer from the Tax Equity Structuring, Financial Modeling and HLBV Accounting Seminar

The tax equity investor invests to own only a portion of the production tax credits (PTCs) up front, since there is an unknown of the actual production levels of the wind farm. What does the project company do with the...more

Navigant’s Consulting’s Report on Residential Solar Misconstrues Value of Tax Attributes

Navigant Consulting on February 19 submitted a report, Solar Project Return Analysis for Third Party Owned Solar Systems, to the Arizona Public Service (APS). The thesis of the report is that residential solar developers are...more

Federal Budget 2016 Extends Mineral Exploration Tax Credit

Canada’s Liberal party released their first Federal Budget on March 22, 2016 since taking office last year. Despite projecting a staggering deficit of approximately $30 billion, the Budget contains welcome news to issuers of...more

Quebec 2016-2017 Budget: Continued Fiscal Discipline

On March 17, 2016, the Quebec government (Government) unveiled the 2016-2017 budget (Budget). The Government confirmed that it balanced the books for 2015–16 and anticipates maintaining a balanced budget for 2016–17. The...more

New Developments in the Determination of the Texas Franchise Tax Liability

The Texas Franchise Tax is imposed on taxable entities that do business in Texas or that are chartered or organized in the state.  Taxpayers subject to the Texas Franchise Tax may compute their tax liabilities under several...more

Budget Announcements: CRC Energy Efficiency Scheme to be Abolished and Climate Change Levy To Be Raised

It has been announced in today’s Budget that the CRC Energy Efficiency Scheme (CRC) will be abolished from 2019 and the Climate Change Levy (CCL) will be raised to compensate. The announcement comes following a...more

MoFo New York Tax Insights - Volume 7, Issue 3, March 2016

TRIAL COURT HOLDS THAT FEES RELATED TO THE NEW YORK HIGHWAY USE TAX ARE UNCONSTITUTIONAL - In a class action lawsuit, an Albany County trial court held that flat highway use registration and decal fees charged to heavy...more

Oregon legislators pass historic renewable energy bill, with 50% RPS and coal-fired electricity phaseout

Oregon legislators passed Senate Bill (SB) 1547 into law yesterday, creating aggressive timetables for eliminating coal-fired electricity from the State and setting a 50% Renewable Portfolio Standard (RPS) by 2040. A diverse...more

Saudi Arabia Update - February 2016

Legal developments - Local partner requirement reported to cease - Saudi Arabia seeks to draw investors to help reduce its reliance on oil exports and aims to facilitate foreign companies' investment in its market....more

Tax Equity Structuring, Financial Modeling and HLBV Accounting

Akin Gump partner, David Burton and Alfa Business Advisors director, Vadim Ovchinnikov hosted a seminar on Tax Equity Structuring, Financial Modeling and HLBV Accounting yesterday. The seminar covered a variety of topics...more

President’s FY 2017 Budget Aims to Seal the Deal on Fiscal Legacy

On February 9, President Obama released the last budget request of his Administration. The FY 2017 budget incorporates many proposals from past years but also looks to cement the president’s legacy with a number of new fiscal...more

Restructuring Oil and Gas Partnership Debt? Tax Planning Is Key

Tax partnerships, including MLPs, seeking to restructure debt face peril and possibility during challenging times. With the lowest oil prices in more than a decade and the equity markets effectively closed to them, oil...more

Tax Equity Market Insights from the Infocast Wind Finance Conference

Below are selected insights from the Infocast Wind Finance conference last week in San Diego. First, as an indicator of the overall interest in wind finance, the conference had twice as many registrants as last year. The...more

Property Tax on Italian Photovoltaic Plants to Decrease Sharply

There is good news for owners of photovoltaic (PV) plants in Italy. In circular no. 2/E, released on 1 February 2016 (the circular), the Italian Revenue Agency has provided official guidance on new rules enacted by on 28...more

Tax Update (Australia): Prospecting for Tax Deductions - The ATO Consolidates and Clarifies Its Views About When Exploration and...

The Commissioner of Taxation has released TR 2015/D4 - Income Tax: deductions for mining and petroleum exploration expenditure (Draft Ruling). The Draft Ruling will replace TR 98/23 - Income Tax: Mining exploration and...more

Congress and the President Find Their Way Along a PATH

As previously reported in the PK Law Newsletter, tax planning for the end of 2015 was hampered by the expiration of a number of “temporary” tax provisions routinely extended for a one or two year period by Congress. Congress...more

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