Engin Nural

Eversheds Sutherland (US) LLP

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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

8/20/2020 / Accumulated Deferred Income Tax (ADIT) , Depreciation , IRS , Popular , Tax Deferral , Utilities Sector

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

12/7/2018 / Corporate Taxes , Cost Allocation , Interest Income , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Tax Cuts and Jobs Act , U.S. Treasury , Utilities Sector

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

10/25/2018 / Bonus Depreciation , Depreciation , IRS , Private Letter Rulings , Tax Rates , Utilities Sector

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

8/13/2018 / Corporate Taxes , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Tax Cuts and Jobs Act , U.S. Treasury , Utilities Sector

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