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Internal Revenue Service Construction Contracts

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Amundsen Davis LLC

Tax Incentives for Green Energy Projects Come With a Lot of Strings Attached

Amundsen Davis LLC on

On August 29, 2023, Clock on Grassthe U.S. Department of the Treasury and the Internal Revenue Service (IRS) released more guidance and proposed rules on key provisions in the Inflation Reduction Act (IRA) that requires...more

Holland & Knight LLP

House and Senate Tax Bills Target Renewable Energy Projects

Holland & Knight LLP on

The U.S. Senate passed its version of a bill to overhaul the U.S. tax code on Dec. 2, 2017, and is now working with the House of Representatives to reconcile its bill with the House's version, passed in November. The goal of...more

Miles & Stockbridge P.C.

IRS Announces Disagreement with Ninth Circuit’s Holding on Completed Contract Method of Accounting

The IRS recently announced its disagreement with the Ninth Circuit’s ruling that, with respect to planned communities, the 95% test under the completed contract method of accounting applies on a development-wide basis rather...more

Miles & Stockbridge P.C.

Obligation to Perform Work and Incur Costs Under Construction Contract is a Section 752 Liability

In a recently issued Private Letter Ruling (PLR 201608001), the IRS determined that a taxpayer-partnership’s obligation to perform work and incur costs under a long-term construction contract constituted a partnership...more

Akin Gump Strauss Hauer & Feld LLP

IRS Comments on its PTC Start of Construction Guidance

On August 20, the American Wind Energy Association (AWEA) held a webinar to discuss Internal Revenue Service (IRS) Notice 2014-46, which clarified the rules for wind projects to be grandfathered for production tax credit...more

McDermott Will & Emery

IRS Issues Additional Guidance with Respect to 2013 Beginning of Construction Rules for Wind and Other Renewable Projects

McDermott Will & Emery on

The Internal Revenue Service (Service) issued Notice 2014-46 (Notice) on August 8, 2014, to provide further guidance on meeting the beginning of construction requirements for wind and other qualified facilities (biomass,...more

Eversheds Sutherland (US) LLP

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

Akin Gump Strauss Hauer & Feld LLP

PTC “Start of Construction” Clarifying Guidance Expected in a Week or Two

General Electric (GE) stated on its quarterly earnings call today that it expected that the clarification to the Internal Revenue Service’s (IRS) production tax credit (PTC) “start of construction” guidance would be released...more

Davis Wright Tremaine LLP

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

K&L Gates LLP

IRS Notice 2013-60 Clarifies Rules on Beginning of Construction

K&L Gates LLP on

On September 20, 2013, the U.S. Department of the Treasury (“Treasury”) released Notice 2013-60, which clarifies in important ways the eligibility rules applicable to the investment tax credit (“ITC”) and production tax...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Notice Clarifying Earlier Guidance on "Beginning of Construction" Requirement for PTC and ITC Purposes

On September 20, 2013, the IRS released Notice 2013-60, which clarified Notice 2013-29. Each Notice addresses the requirement that construction of a qualified facility must begin before January 1, 2014, in order to be...more

Akin Gump Strauss Hauer & Feld LLP

IRS Provides Helpful Clarification to PTC “Start of Construction” Rules

On September 20th, the IRS in Notice 2013-60 clarified three critical issues in its guidance as to whether a wind project (or other type production tax credit (PTC) eligible project) is considered to have “started...more

Stoel Rives LLP

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

Stoel Rives LLP on

On September 20th, the IRS issued Notice 2013-60, which updates prior guidance, contained in Notice 2013-90, regarding the "begin-construction" requirement for the production tax credit (PTC) under Section 45 of the Internal...more

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