The IRS recently released guidance in the form of an IRS Notice implementing a rule change under the American Taxpayer Relief Act of 2012 concerning the construction deadline that renewable energy facilities must meet to...more
On April 25, 2013, the Internal Revenue Service updated guidance issued on April 15, 2013, that explained how to satisfy the new “begun construction” requirement for the renewable energy section 45 production tax credit (PTC)...more
On April 15, 2013, the Internal Revenue Service (IRS) issued long-awaited guidance updating eligibility requirements for renewable project developers seeking to utilize the 2.3 cent/kWh Renewable Electricity Production Tax...more
Long-awaited guidance regarding eligibility for production or investment tax credits largely tracks guidance under the Section 1603 cash grant program....more
On April 15, 2013, the Internal Revenue Service ( IRS) issued much - anticipated guidance that will help developers of wind, solar, biomass and certain other renewable energy facilities qualify for federal renewable energy...more
The IRS wrote yesterday in the Federal Register that it is increasing the amount that developers of wind and some other renewable projects can receive via the production tax credit. The credit was set at 1.5 cents per...more
Last week, a group of U.S. Senators submitted a letter requesting swift clarification by the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) of language regarding the wind production tax...more
Sponsors and investors have been paying much attention to the potential use of real estate investment trust (REIT) structures to hold and finance renewable energy assets in a tax-efficient way. A recent SEC filing by Hannon...more
The Internal Revenue Service (IRS) recently revoked Private Letter Ruling (PLR) 201214007, which found that facility-specific power purchase agreements (PPAs) are considered part of the underlying wind energy facilities and,...more
Two recent developments may impact Section 1603 renewable energy Treasury grant program awards: (1) audits of grant recipients by the Internal Revenue Service (IRS) and Department of the Treasury’s Office of Inspector General...more
Tax credit investors received a big boost from the U.S. Tax Court in Historic Boardwalk Hall LLC v. Commissioner, 136 TC No. 1 (January 3, 2011). The court upheld a partnership structured to generate historic rehabilitation...more
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