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
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
6/27/2018
/ Begun Construction Test ,
Energy Projects ,
Energy Sector ,
Investment Tax Credits ,
IRS ,
New Guidance ,
Physical Work Test ,
Production Tax Credit ,
Renewable Energy ,
Safe Harbors ,
Solar Energy
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
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
The Bipartisan Budget Act of 2018 (2018 BBA) passed by Congress and signed into law on February 9, 2018, extends and changes tax credits for the renewable energy, alternative fuels and nuclear energy industries, and also...more
The Tax Extender Act of 2017 (Extenders Bill) would, if enacted, extend and change tax credits for the renewable energy, alternative fuels and nuclear energy industries, and also would make other changes relevant to the...more
On December 22, 2017, the President signed into law the bill formerly known as the Tax Cuts and Jobs Act (the Final Bill). This alert summarizes the principal provisions affecting Section 529 Qualified Tuition Programs and...more
On December 15, 2017, the House-Senate Conference Committee released a revised version of the Tax Cuts and Jobs Act (the Final Bill) that is expected to be passed by the House of Representatives and Senate this week and sent...more
On November 1, 2017, the District of Columbia will begin implementing a new sales and use tax exemption application process for Qualified High Technology Companies (QHTCs). Previously, QHTCs could provide sales and use tax...more
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
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
On May 5, 2016, the Internal Revenue Service (IRS) issued Notice 2016-31, which updates prior guidance regarding the beginning of construction requirement for IRC sections 45 and 48 renewable energy tax credits following...more
5/6/2016
/ Begun Construction Test ,
Energy Projects ,
Guidance Update ,
Internal Revenue Code (IRC) ,
IRS ,
Physical Work Test ,
Protecting Americans from Tax Hikes (PATH) Act ,
Renewable Energy Incentives ,
Safe Harbors ,
Tax Credits ,
Wind Power