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IRS issues final regulations on section 468A nuclear decommissioning costs

On September 3, 2020, the Internal Revenue Service (IRS) released long-awaited final regulations (Final Regulations) under section 468A of the Internal Revenue Code of 1986, as amended (Code). The Final Regulations generally...more

PLR on the normalization of cost of removal and accounting method changes for repairs and mixed service costs, but questions...

On August, 15, 2020, the Internal Revenue Service (IRS) issued PLR 202033002, in which it addressed whether cost of removal (COR) is “protected” by the normalization rules of section 168(i)(9). COR is often embedded in a...more

“But wait, there’s more.” – Rev. Proc. 2020-39 provides guidance on the proper treatment of excess deferred taxes, and other...

On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more

IRS provides COVID-19-related relief for renewables

On May 27, 2020, the IRS issued Notice 2020-41, which provides much needed COVID-19-related relief from workforce and supply chain issues impacting the renewable energy industry. The Notice provides the following: ..For PTC...more

IRS reaffirms stance on public utility property for wind energy facility, but again declines to address I.R.C. Sec. 707(b) issue

In PLR 202020011, the Internal Revenue Service (IRS) reaffirmed that a wind energy facility owned by a utility affiliate and unrelated investor in a LLC taxable as a partnership was not “public utility property” because the...more

IRS releases 2020 section 45 production tax credit amounts

The Internal Revenue Service (IRS) recently published a notice providing the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy production tax credits under Internal Revenue...more

Normalization ruling covers new ground on supplemental rate proceedings and depreciation-related section 481 adjustments 

On March 6, 2020, the Internal Revenue Service (IRS) released PLR 202010002, which provided the appropriate normalization treatment of infrastructure surcharges in supplemental rate proceedings as well as the proper...more

IRS rules no violation of normalization requirements in computation of pro rata portion of ADIT used to reduce rate base

In a recent private letter ruling (PLR 201949006), the Internal Revenue Service (IRS) addressed the computation of the pro rata portion of accumulated deferred federal income tax reserve (ADFIT, together with the total...more

Ready, fire, aim - IRS Chief Counsel Advisory misses the mark in NOL carryforward position that controvenes the TCJA

In CCA 201928014 (July 12, 2019), the IRS Office of Chief Counsel provides its view of the interplay between the net operating loss (NOL) carryover rules set forth in Internal Revenue Code (Code) § 172(b)(2) and the...more

IRS clarifies the corrective measures a regulated transmission utility must undertake to avoid a normalization violation

In two recent private letter rulings (PLRs 201930015 and 201930016), the Internal Revenue Service (IRS) clarified the corrective measures a regulated transmission utility must undertake to avoid a normalization violation. In...more

IRS reaffirms that negotiated rates under PPA prevents solar facility from classification as “public utility property”

In Private Letter Ruling 201923019 (Feb. 21, 2019) (publicly released on June 10, 2019), the Internal Revenue Service (IRS) addressed a state statute that allowed a regulated public utility to acquire an unregulated solar...more

IRS releases 2019 section 45 production tax credit amounts

The Internal Revenue Service (IRS) recently published a notice providing the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy production tax credits under Internal Revenue...more

IRS releases 2019 inflation adjustment for section 45Q carbon oxide sequestration credit

On May 13, 2019, the Internal Revenue Service (IRS) released Notice 2019-31, which provides the 2019 inflation adjusted amounts for the section 45Q carbon oxide sequestration credit. The section 45Q carbon oxide sequestration...more

IRS requests comments on the normalization requirements relating to excess tax reserves resulting from the Tax Cuts and Jobs Act

On May 7, 2019, the Internal Revenue Service (IRS) released Notice 2019-33 (Notice) announcing its intention to issue guidance under section 168 of the Internal Revenue Code to clarify the normalization requirements for...more

IRS requests comments on section 45Q carbon sequestration credit in Notice 2019-32

On May 2, 2019, the Internal Revenue Service (IRS) released Notice 2019-32 (Notice) requesting comments on anticipated regulations and other guidance under section 45Q of the Internal Revenue Code. Section 45Q was originally...more

Proposed 163(j) regulations provide needed guidance to utilities

On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more

What you need to know about investing in opportunity zones

As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities designated as “Opportunity Zones.”...more

IRS tells utility not to count its (deferred tax) chickens before they hatch

The affiliated group of which a taxpayer-utility was a wholly owned subsidiary filed tax returns on which it did not claim bonus depreciation since the availability of bonus depreciation had temporarily expired. Following the...more

Proposed 168(k) regulations offer several surprises for utilities and present challenges with uncertainties left unaddressed

The proposed regulations under section 168(k) issued by Treasury and the Internal Revenue Service (IRS) on August 3, 2018, not only presented utilities with some surprises, but also raised concerns as a result of unaddressed...more

IRS rules that a method of reflecting a federal income tax settlement in ratemaking violated the consistency rule of normalization

In PLR 201828010, the Internal Revenue Service (IRS) considered the proper ratemaking treatment for reflecting the results of a federal income tax settlement. The taxpayer was a member of an affiliated group filing...more

The long-awaited “solar beginning of construction notice” - Notice 2018-59 provides guidance for solar and other section 48...

On June 22, 2018, the Internal Revenue Service (IRS) issued much-anticipated guidance to help developers of, and other industry participants in, solar, qualified fuel cell, qualified microturbine, combined heat and power,...more

IRS releases 2018 section 45 production tax credit amounts

The Internal Revenue Service (IRS) recently published Revenue Procedure 2018-50, which provides the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy production tax credits...more

IRS Clarifies Revenue Procedure 2017-47 Safe Harbor for Inadvertent Normalization Violations

On February 23, 2018, the Internal Revenue Service (IRS) released Generic Legal Advice Memorandum (GLAM) 132120-17, clarifying Revenue Procedure 2017-47.1 This GLAM clarifies that the phrase “in a manner that totally reverses...more

3/1/2018  /  IRS , Revenue Procedures

IRS Further Updates Beginning of Construction Guidance for Renewable Energy Tax Credits

On December 15, 2016, the Internal Revenue Service (IRS) issued Notice 2017-04, which updates prior guidance regarding the beginning of construction requirement for renewable energy tax credits under IRC sections 45 and 48. ...more

Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities 

Amid the Panama Papers leak and international concern that foreign persons were concealing assets through U.S. entities that are disregarded for U.S. federal income tax purposes, the Internal Revenue Service (IRS) and the...more

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