News & Analysis as of

Transfer of Interest

Fenwick & West LLP

Rawat Creates a Ripple in Statutory Interpretation Principles

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Recently, in Rawat v. Commissioner, the D.C. Circuit reversed the Tax Court decision and held that a foreign partner would not be subject to U.S. tax on selling an interest in a partnership with “hot assets” subject to §...more

Fox Rothschild LLP

NJ Appellate Court Outlines LLCs' Path to Rescind Erroneous Certificates of Dissolution

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A recent New Jersey appellate decision underscores the need for the leaders of limited liability companies (LLCs) to consider how to eliminate the risk of fraudulent, inaccurate or mistaken filings by former members and...more

Gray Reed

Fraud in an Oil Deal Revealed after Nine Years

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In the Estate of Larry Wayne Ewers is a reminder of a few guidelines for oil and gas investing:   Think twice before giving money to your scripture-spouting friend from church....more

Womble Bond Dickinson

IRS Publishes Final Regulations for Transfer of Certain Credits

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The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code (the “Code”) to allow taxpayers to sell certain Federal income tax credits....more

Holland & Knight LLP

Treasury Department and IRS Release Final Regulations on the Transfer of IRA Tax Credits

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As provided in the Inflation Reduction Act (IRA), eligible taxpayers may make a yearly election to transfer all (or any portion) of an eligible credit to an unrelated taxpayer under Section 6418 of the Internal Revenue Code,...more

Vinson & Elkins LLP

The AIEN 2023 International Model Joint Operating Agreement

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The article examines the JOA’s main provisions, including rights and duties of the operator, operating committee, work programs and budgets, contract awards, greenhouse gas provisions, exclusive operations, default,...more

Tonkon Torp LLP

Lawsuits Don’t Often Make Your Dreams Come True

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The recent legal clash between Daryl Hall and John Oates highlights key lessons about partnership dynamics and the necessity for a well-crafted partnership agreement. Their conflict, while centered on assets derived from...more

International Lawyers Network

Establishing a Business Entity in Brazil (Updated)

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they ...more

Haynsworth Sinkler Boyd, P.A.

HSB Economic Development Update - December 2023

The HSB Economic Development team published their December 2023 news update, highlighting the following topics: 2024 County Tiers Set for JTCs, Fee in Lieu and Tax Moratorium- Each year, South Carolina's 46 counties are...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Long-Awaited Proposed Regulations on Section 48 Investment Tax Credits

On November 17, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) regarding the investment tax credit (ITC) under...more

Ballard Spahr LLP

Expansion of Montgomery County ROFR

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County Council President Evan Glass introduced Expedited Bill 38-23 to modify the Montgomery County, Maryland (County) right of first refusal (ROFR) law to permit the County to assign its ROFR rights to a “qualified entity.”...more

Goodwin

The Fintech Deal Long Pole: License Change of Controls

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In this edition of Fintech Flash, we discuss important things you should know about the change of control requirements when acquiring a fintech company with state lender, loan broker, debt collector, or money transmitter...more

Stradling Yocca Carlson & Rauth

The Unexpected Complexities of Transferring an Ownership Interest in a Limited Liability Company – And How to Navigate Them

Limited Liability Companies (LLCs) are a common business structure. Combining the best elements of corporations and partnerships, LLCs offer liability protection while maintaining operational flexibility....more

Eversheds Sutherland (US) LLP

Directions regarding Direct Pay - Proposed Regulations Released on Elective Payment for Inflation Reduction Act Renewable Energy...

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more

Eversheds Sutherland (US) LLP

Treasury and IRS release proposed regulations on transferability of IRA renewable energy credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more

Latham & Watkins LLP

IRS Proposed Rules Explain How Taxpayers Can Buy and Sell Renewable Energy Tax Credits or Receive Cash Refunds

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The proposed rules for monetizing tax credits should catalyze energy transition markets and offer an alternative to tax equity transactions. On June 14, 2023, the IRS issued proposed rules for how it intends to administer...more

Paul Hastings LLP

Treasury and IRS Issue Long-Awaited Guidance on Energy Tax Credit Transfers

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The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code of 1986, as amended (the “Code”), which allows taxpayers to elect to transfer all or any portion of certain energy tax credits to an...more

Holland & Knight LLP

Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

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The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more

BakerHostetler

Overview of the Proposed Regulations Addressing Transferring Renewable Credits

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As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more

Fox Rothschild LLP

Is a Gift a Gift if You Don’t Know You Got it?

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The issue of gifting comes up with some frequency in family law cases. Generally, gifts from third parties that are not subsequently commingled are exempt from equitable distribution. Parties also make gifts to children and...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release much-anticipated guidance, including with respect to the monetization of energy tax credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a package of much-awaited guidance (the Guidance) consisting of (i) proposed regulations addressing the tax credit...more

Holland & Knight LLP

Treasury Department and IRS Release Direct Pay and Transferability Guidance

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The U.S. Department of the Treasury and IRS on June 14, 2023, released two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax credits under Section 6417 of the Internal Revenue Code (Elective Payment...more

BCLP

The Transferability of Tax Credits: the Creation of Secondary Market Under the Inflation Reduction Act

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The Inflation Reduction Act of 2022 (the “IRA”) represents the largest investment in clean energy and climate change in the history of the United States, with over $370 billion of funding to provide tax credits for clean...more

Venable LLP

The Right of Publicity

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Social media has confirmed that you don’t need to be a celebrity to profit from your own image. The right of an individual to control the economic use and exploitation of his or her identity is called the right of publicity....more

Farrell Fritz, P.C.

Operating Agreement Trumps Postnup in High Stakes Battle Over Transfer of LLC Interest

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Husband owns 99% membership of manager-managed LLC. Children own remaining 1%. Postnuptial agreement says husband’s “interest” in LLC goes to wife. LLC agreement says any transferee is not admitted as a member absent the...more

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