Safe Harbors Internal Revenue Service

News & Analysis as of

IRS Issues New Guidance on the Beginning of Construction Safe Harbor For Renewable Energy Projects

The IRS recently issued Notice 2017-4 (the “Notice”) which makes two important changes to its “beginning of construction” rules for taxpayers seeking to take advantage of the section 45 renewable electricity production tax...more

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

On December 15, 2016, the Internal Revenue Service released Notice 2017-04, which provides welcome guidance on how to meet the “beginning of construction” requirements for wind and other qualified facilities. There has been...more

IRS Issues Notice 2017-04, Further Clarifying and Extending the "Begun Construction" Requirements for ITCs and PTCs

On December 15, 2016, the IRS issued Notice 2017-04, which clarifies and extends certain "begun construction" requirements for facilities qualifying for the Section 45 production tax credit (PTC) for which construction must...more

IRS Issues Welcome Guidance on “Continuity Safe Harbor” for Wind Energy Projects

New rules provide wind developers with additional time to satisfy a critical safe harbor. On December 15, 2016, the Internal Revenue Service (IRS) issued Notice 2017-4, which modifies the “continuity safe harbor” as set...more

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

Higher Education, Exempt Organization & Governmental Financings - Tax Presentation

Qualified Equity - Allocation & Accounting Rules for Private Business Use - New Treasury Regulations regarding measurement and allocation of private business use (PBU) benefit universities that finance a...more

Do You Need to Send an Annual Notice to Plan Participants? If So, You May Need to Do So by December 1, 2016*

Plan sponsors of defined contribution qualified plans may need to issue one or more annual notices to participants before the end of each plan year. Failure to issue a required annual notice can have significant consequences....more

IRS Eases Safe Harbor Conditions Under Which a Contract with a Hospital Will Not Result in Private Business Use of Tax-Exempt...

Under federal income tax law, the tax-exempt status of a bond is jeopardized if the proceeds of the bond are used for a private business use. Because hospital facilities are often financed with tax-exempt bonds, hospital...more

November and December 2016 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...more

Rev. Proc. 2016-44: Greater Flexibility in IRS Safe Harbor for Management Contracts

Recently, the IRS released a safe harbor from private use of tax-exempt bond-financed facilities for management contracts that profoundly changes the safe harbors that have been in place under Rev. Proc. 97-13 for almost 20...more

Come On In and Stay Awhile: IRS Expands Safe Harbors for Bond-Financed Property

The Internal Revenue Service recently issued guidance in Rev. Proc. 2016-44 that meaningfully expands the safe harbors pertaining to management contracts affecting bond-financed property such as professional services...more

IRS Continues Trend of Flexibility for Qualified Management Agreements (QMA’s) for Hotels Financed With Tax Exempt Bonds

The US Internal Revenue Service (IRS) recently continued a trend of pronouncements further extending flexibility in structuring a Qualified Management Agreement (QMA) for a hotel financed with tax exempt bonds without...more

IRS Releases Guidance on Management Contracts

Revenue Procedure 2016-44 replaces the long-standing safe harbors in Revenue Procedure 97-13 for analyzing private business use under management contracts with a more flexible safe harbor, but requires specific provisions in...more

Update to August 24th Safe Harbors Client Alert - NEW TRANSITION PERIOD

Update to August 24th Client Alert: Note: As published September 6, 2016 in the Internal Revenue Bulletin, the Internal Revenue Service has extended the transition period with respect to Revenue Procedure 2016-44 to...more

IRS Issues New Management Contract Safe Harbors

On Monday, August 22, the Internal Revenue Service (“IRS”) issued Revenue Procedure 16-44 (“Rev. Proc. 16-44”), which revises and expands the safe harbor provisions for long-term management contracts relating to property...more

New Management Contract Safe Harbors

The Internal Revenue Service (the “IRS”) released Revenue Procedure 2016-44 (“Rev. Proc. 2016-44”) on August 22, 2016 to provide new safe harbors for management contracts to avoid characterization of such contracts as private...more

IRS Releases New Management Contract Safe Harbors For Bond-Financed Property

On August 22, 2016, the Internal Revenue Service (IRS) released Revenue Procedure 2016-44 (2016-44) and then modified 2016-44 on September 2, 2016. This revenue procedure was a response from the IRS to a longstanding request...more

What is Telemedicine? A Cool Benefit or a Hot Mess?

We’ve had numerous inquiries lately about telemedicine benefits. My clients most typically ask either “is this a group health plan?” or “is it just access to another provider?” Clearly, there is much confusion surrounding...more

IRS releases updated safe harbors for management contracts in tax-exempt bond-financed projects

On August 22, 2016, the Internal Revenue Service released Revenue Procedure 2016-44. The purpose of this revenue procedure is to provide revised and broader “safe harbors” under which certain private management contracts will...more

IRS Loosens Restrictions on Safe Harbors for Management Contracts for Bond-Financed Property

The Internal Revenue Service, in Revenue Procedure 2016-44, has loosened the restrictions on safe harbors for management contracts entered into by governmental issuers of tax-exempt bonds in connection with facilities...more

New IRS Management Guidance is Flexible, Furthers P3s

State and local governments and 501(c)(3) organizations have been given very flexible guidance by the IRS for longer-term private management of tax-exempt bond financed projects to facilitate general operations and major...more

IRS Publishes New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

On August 22, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-44, which provides new guidance on the treatment of “management contracts” for purposes of the restrictions on use of property financed with...more

IRS Relaxes Restrictions on Management Contracts for Bond-Financed Facilities

The IRS on August 22, 2016 released long-anticipated Revenue Procedure 2016-44 (Rev. Proc. 2016-44), which substantially increases flexibility in, and provides a less formulaic approach to, the ability of a tax-exempt bond...more

Client Alert: New Safe Harbors for Management Contracts of Tax-Exempt Financed Facilities

The Internal Revenue Service on August 22, 2016 released Revenue Procedure 2016-44 which revises the safe harbor guidelines for management contracts of service providers for tax-exempt financed facilities, under which the...more

IRS Issues New Management Contract Safe Harbors

Almost 20 years ago, the IRS released Rev. Proc. 97-13, outlining multiple safe harbors under which a management contract would not result in private business use of bond-financed proceeds. These safe harbors, while helpful,...more

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