PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements. For this reason, Investors and managers should understand the basics of PIP allocations and whether and when they...more
Forming a partnership1 without triggering income appears straightforward and simple. In many cases, it is. In other cases, though, forming a partnership can cause one or more partners to unintentionally recognize income. This...more
8/27/2024
/ Asset Diversification ,
Capital Structures ,
Debt Financing ,
Disguised Sales ,
Equitable Contribution ,
Foreign Persons ,
Investment Companies ,
IRS ,
Liability ,
Partnership Interests ,
Partnerships ,
Stocks
The Inflation Reduction Act (the IRA) awards renewable energy tax credits1 for creating (or investing in) property that produces or generates renewable energy and clean energy fuels. Those credits are enhanced if the...more
7/24/2024
/ Apprenticeships ,
Contractors ,
Davis-Bacon Act ,
Energy Projects ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
IRS ,
Prevailing Wages ,
Renewable Energy ,
Subcontractors ,
Tax Credits ,
U.S. Treasury
The Internal Revenue Service (IRS) issued Notice 2024-41 on May 16, 2024. Notice 2024-41 guides taxpayers on qualifying for increased renewable energy tax credits. To qualify for this credit increase, a taxpayer must satisfy...more
The United States Department of Treasury issued final regulations (Final Regulations) that arguably change the test (DC Test) for determining whether a REIT is a domestically controlled qualified investment entity (DC-REIT)....more
The Tax Court recently ruled that a limited partner’s share of business income may be earnings from self-employment. Earnings from self-employment are subject to the self-employment tax.
Earnings from self-employment...more
On November 22, 2023, the Internal Revenue Service published proposed regulations concerning Sections 48, 6417, and 6418. These proposed rules would affect the conditions for claiming energy credits, the amount of energy...more
11/28/2023
/ Apprenticeships ,
Carbon Capture and Sequestration ,
Department of Energy (DOE) ,
Energy Projects ,
Investment Tax Credits ,
IRS ,
Prevailing Wages ,
Production Tax Credit ,
Renewable Energy ,
Tax Credits ,
Tax Exemptions