Investment Tax Credits

News & Analysis as of

ML Strategies Energy and Environment Update - August #3

This week, ML Strategies’s Director of Government Relations, Bryan Stockton, provides an update on the clean energy provisions in the Senate’s tax-extenders package and details scenarios for their extension as the midterm...more

IRS Clarifies and Expands "Beginning Construction" Tests for Production Tax Credit and Investment Tax Credit

In 2013, the Internal Revenue Service established two “beginning construction” tests – a physical work test and a 5% safe harbor test – to determine eligibility for the production tax credit (PTC) and investment tax credit...more

IRS Releases New Guidance on Beginning of Construction

The IRS recently released Notice 2014-46 (the Notice) which provides welcome guidance to tax equity investors and developers on the construction of wind, geothermal, biomass, landfill gas and certain hydropower and marine...more

Notice 2014-46 Provides Additional Guidance on Eligibility of Wind and Other Renewable Energy Facilities for the PTC or the ITC

On August 8, 2014, the Internal Revenue Service (IRS) released Notice 2014-46 (the “Notice”), which provides some important clarifications with respect to the requirement that construction of a project commence prior to...more

IRS Notice 2014-46 clarifies guidance for Production Tax Credits and Investment Tax Credits

The American Taxpayer Relief Act of 2012 modified the definition of certain “qualified facilities” under Section 45(d) of the Internal Revenue Code to require that the construction of such facilities must begin prior to...more

IRS Releases New Guidance on Beginning of Construction - Aug 2014

On August 8, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-46 (the “Notice”), which clarified certain aspects of the beginning of construction requirement that must be satisfied for taxpayers to qualify for...more

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

IRS Relaxes and Clarifies Renewable Energy Tax Credit Eligibility Requirements for Projects Under Construction

On August 8, 2014, the Internal Revenue Service (IRS) issued Notice 2014-46 in response to continued industry requests for clarification on several aspects of the renewable electricity Production Tax Credit (PTC) under...more

Are You Really Sure That Construction Began? IRS Issues Third Notice Regarding Renewable Energy Tax Credit Beginning of...

On August 8, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-46, which provides further guidance intended to assist developers and purchasers of renewable energy facilities evaluate whether such facilities...more

IRS Issues Additional Guidance on "Start of Construction" Requirement for Renewable Energy Tax Credits

On August 8, 2014, the IRS released Notice 2014-46, which provides additional guidance on the "start of construction" requirements for the investment tax credit (ITC) and production tax credit (PTC). As discussed below,...more

Energy Tax Law Alert: IRS Issues New Guidance Regarding Beginning of Construction Requirement for ITC/PTC

On Friday, the IRS issued guidance that clarifies and modifies prior guidance regarding the “beginning of construction” requirement for qualifying for the production tax credit (PTC) under Section 45 of the Internal Revenue...more

IRS Finally Releases Clarifications to PTC “Start of Construction” Guidance

On Friday, the Internal Revenue Service (IRS) issued Notice 2014-46, which clarifies the rules for a wind project to be deemed to have started construction in 2013 as is necessary to be eligible for production tax credits...more

IRS Issues Notice on the Cash Grant Sequestration and Tax Attributes

Yesterday, the IRS issued a notice confirming the effects of the Cash Grant sequestration with respect to the tax attributes associated with the renewable energy projects that received the Cash Grant. Notice 2014-39 is...more

PTC Extension Added to Tax Extenders

A modified extenders package was released today that includes a two-year extension of the renewable energy production tax credit (PTC) under section 45 of the Internal Revenue Code as well as an extension of the option to...more

Senate Finance Committee Tax Reform Proposal Streamlines Energy Tax Credits

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

IRS Revises Historic Tax Credit Revenue Procedure

Revenue Procedure 2014-12 provides a safe harbor for historic tax credit (i.e., the Section 47 rehabilitation tax credit) partnership transactions. On January 8, the IRS issued a revised version of it that provides a...more

Contemplating IRS Safe Harbor for Rehabilitation Credits and Its Impact on the Energy Investment Tax Credit

The IRS recently issued Revenue Procedure 2014-12, providing a safe harbor under which the IRS will not challenge partnership allocations of “section 47” federal rehabilitation tax credits. In the aftermath of the IRS’s win...more

Baucus Proposes Reforms to Energy Tax Incentives

Senate Finance Committee Chairman Max Baucus (D-MT) released a proposal on December 18 that would streamline energy tax incentives to make them more predictable and technology-neutral. The proposal consolidates several...more

Baucus Post-2016 Proposal: No Change to PTC & ITC Reduced to 20 Percent

Today, the chairman of the Senate Finance Committee, Max Baucus (D-MT), released his proposal for energy tax incentives as part of overall tax reform. The proposal is thoughtful and merits serious consideration by the...more

IRS Opens the Door to Expanded Use of Residential Section 25D Credit in Offsite Solar and Other Renewables Projects

The IRS has released new guidance (Notice 2013-70) (the “Guidance”) in the form of a Q-and-A interpreting tax credits available to individual taxpayers under IRC Section 25D (Residential Energy Efficient Property) (the “25D...more

New Energy Finance Paper Discusses Tax Equity

America’s Power Plan describes itself as a “toolkit” for policymakers. The information that constitutes the toolkit is available below. Its energy finance paper was just published. The paper is available below. Below are...more

IRS Clarifies Guidance for Determining When Construction Has Begun for the Production Tax Credit and Investment Tax Credit

On September 20, 2013, the IRS released Notice 2013-60 (the “Notice”), clarifying the requirements that must be satisfied in order for certain renewable energy facilities to qualify for the Production Tax Credit (“PTC”) and...more

New Beginning Construction Guidance Notice 2013-60

Earlier this year, the Internal Revenue Service (the “IRS”) published Notice 2013-29, providing guidance on what it means to “begin construction” for purposes of the recent extension of the 2.3 cent-per-kilowatt-hour...more

IRS Issues Additional Guidance on When Construction Begins for Purposes of Production Tax Credit, Investment Tax Credit

The Internal Revenue Service (IRS) has issued additional guidance relating to when construction begins with respect to wind and other qualified facilities for purposes of the production tax credit and investment tax credit. ...more

Energy Law Alert: IRS Releases Notice 2013-60 With Additional Guidance For PTC/ITC Qualification

Late in the day on September 24, the IRS released a formal Notice addressing the Begun Construction requirements to qualify for the Production Tax Credit and Investment Tax Credit. Notice 2013-60 clarifies an earlier Notice...more

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