Production Tax Credit

News & Analysis as of

IRS Issues Fourth Production Tax Credit Guidance

The Internal Revenue Service recently issued the expected Notice 2015-25, which supplements its earlier notices on the same subject and provides additional guidance to renewable energy facility developers and investors when...more

IRS Issues Additional Guidance on Beginning of Construction Rules for Renewable Projects

The Internal Revenue Service (IRS) issued Notice 2015-25 (Notice) on March 11, 2015, to provide further guidance on meeting the beginning of construction requirements for wind and other qualified facilities (biomass,...more

Are You Continuing Construction? IRS Issues Fourth Renewable Energy Tax Credit Beginning of Construction Notice

On March 11, 2015, the Internal Revenue Service (IRS) issued Notice 2015-25, which provides further guidance to assist renewable energy facility developers and investors in evaluating whether such facilities satisfied the...more

IRS Issues Notice 2015-25 Extending Safe Harbor for Continuous Construction in Order to Take Advantage of Renewable Energy Tax...

Thursday, the IRS issued Notice 2015-25, which updates the guidance in Notices 2013-29, 2013-60, and 2014-46. These Notices provide that a taxpayer can show that it has “begun construction” of its qualified renewable energy...more

IRS Extends Safe Harbor for Completion of PTC-Qualifying Facilities to Jan. 2017

Yesterday, March 11, 2015, the Internal Revenue Service issued Notice 2015-25, which extends by one year certain tests taxpayers can use to establish that a qualifying renewable energy facility is eligible for the production...more

IRS Extends Continuous Construction/Continuous Efforts Safe Harbors for Production Tax Credit/Investment Tax Credit Qualification

Production tax credits (“PTCs”) are available for wind, biomass, geothermal, landfill gas, trash, hydropower, and marine and hydrokinetic facilities, if construction of the facility began before January 1, 2015....more

IRS Publishes Favorable Guidance on PTC “Start of Construction” Rules

Today, the IRS published Notice 2015-25 that provides guidance the wind power industry has been waiting for since the extension of the production tax credit (PTC) in December....more

IRS Extends "Begun Construction" Guidance

Earlier yesterday, the IRS released Notice 2015-25, 2015-13 IRB 1, which updates the guidance provided in Notice 2013-29, 2013-1 C.B. 1085, Notice 2013-60, 2013-2 C.B. 431, and Notice 2014-46, 2014-36 I.R.B. 520...more

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

The IRS today issued Notice 2015-25, updating its prior guidance in Notices 2013-29, 2013-60, and 2014-46, regarding the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the...more

Key Energy-Related Tax Provisions in the 2016 Budget Proposal

In This Issue: - Modify and Permanently Extend the Production Tax Credit - Enhance and Make Permanent the Research and Experimentation Tax Credit - Provide Carbon Dioxide Investment and Sequestration Tax...more

Sound Bites from Infocast Wind Finance 2015

The Infocast Wind Power Finance & Investment Summit 2015 was held from February 10 to 12 in San Diego. Below are selected sound bites regarding the tax equity market and other finance related matters....more

Obama Administration’s FY 2016 budget would modify LIHTCs, permanently extend NMTC and energy tax credits

As in prior years, the Obama administration’s FY 2016 budget includes a number of impactful, and generally positive, tax credit proposals. With respect to the Low-Income Housing Tax Credit (LIHTC), the budget retains many of...more

Renewable Energy Update - January 2015 #2

Renewable Energy Focus - California Governor Brown calls for 50 percent renewables by 2030 - Greentech Media - Jan 5: California Governor Jerry Brown has upped the ante on the state’s green energy goals, calling...more

Production Tax Credit Extended for Renewable Projects Beginning Construction in 2014

On December 19, 2014, President Obama signed into law the Tax Increase Prevention Act of 2014 (H.R. 5771). H.R. 5771 includes a retroactive one-year extension of the section 45 renewable electricity production tax credit...more

Rectification is About Intention – Not Interpretation

The Ontario Superior Court of Justice recently granted rectification in a case in which the CRA and the taxpayer differed in their interpretation and effect of a particular document. In Kaleidescape Canada Inc et al v...more

Tax Extenders Signed into Law; Production Tax Credit Extended for Facilities Beginning Construction in 2014

Earlier today, President Obama signed the Tax Increase Prevention Act of 2014 (H.R. 5771) into law, following its passage through Congress on Tuesday. Among other things, the act will provide a one-year retroactive extension...more

Energy Tax Alert: Congress Extends Renewable Energy Credits

Congress this week passed the Tax Increase Prevention Act of 2014, which extends a number of expired or expiring tax provisions through the end of 2014. The President is expected to sign the Act soon. The Act renews several...more

Senate Passes PTC Extension for 2014

The Tax Increase Prevention Act of 2014, H.R. 5771, was passed by the Senate on December 16 and by the House on December 3. The President is expected to sign the bill in the coming days. ...more

House Approves Energy Tax Extenders

Last week, the U.S. House of Representatives (House) overwhelming approved a $42 billion tax extenders bill. The bill, H.R. 5771, includes extensions of nearly $10 billion in energy tax incentives through the end of 2014. ...more

House Passes PTC Extension through End of 2014

Today, the House passed H.R. 5771. To become law, H.R. 5571 must still pass the Senate and be signed by the President. We expect both of those steps will occur by the end of the year....more

Renewable Energy Update -- November 2014

Renewable Energy Focus - U.S. solar consolidation seen before tax credit expires: Bloomberg - Oct 20: Acquisitions in the solar industry will accelerate as manufacturers and developers prepare for the expiration of a...more

Pre-election PTC Extension Update

With the election on Tuesday, the wind industry’s attention is particularly focused on the prospects for the extension of the production tax credit (PTC). There have been four interesting developments related to the extension...more

CRS Report on the Production Tax Credit

On October 2, the Congressional Research Service (CRS) published an overview of the production tax credit (PTC). The report is available below. It contains a helpful summary of the history of the PTC and an insightful...more

Joint Committee’s Report on Energy Tax Incentives Misses the Mark on Green Jobs

The Joint Committee on Taxation (JCT) on September 16 published a report analyzing federal energy tax incentives. The report is available below. The report is generally insightful; however, it has a misguided job-creation...more

High Net Worth Family Tax Report, Vol. 9, No. 2

What You Need to Know About Corporate Inversions - It seems like every day brings news of another possible corporate inversion transaction. The news reports usually describe these transactions as another United States...more

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