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2019 Tax Credit Inflation Adjustment Factor: 2.5 Cents per kWh for Wind Facilities

The Internal Revenue Service recently published its annual notice providing the inflation adjustment factors and reference prices used in determining the amount of production tax credits (PTCs) for renewable energy and...more

Beginning Construction Continuity Safe Harbor Extended for National Security Concerns

Earlier this month, the Internal Revenue Service issued Notice 2019-43, which modifies guidance provided in prior Notices 2013-29, 2013-60, 2014-46, 2015-25, 2016-31, 2017-04 and 2018-59 to provide that the continuity safe...more

Advanced Issues for DPM & PPM Transactions and Platforms: Business Tax Issues in Light of Tax Reform – Key Takeaways

The next in our series of posts sharing key takeaways from panels at the Healthcare & Life Sciences Private Equity and Lending Conference discusses investing in designated primary market makers and private placement...more

Treasury Releases Second Round of Proposed Regulations to Encourage Investment in Opportunity Zones

On April 17, 2019, the Department of Treasury and Internal Revenue Service released another set of proposed regulations on the Opportunity Zone (OZ) tax benefit. Until recently, many investors, funds, business owners and real...more

Key Takeaways From the BEAT Proposed Regulations

On Dec. 13, 2018, the Internal Revenue Service and Department of Treasury issued proposed regulations addressing the base erosion and anti-abuse tax (BEAT). In general, the regulations provide guidance for identifying an...more

Key Takeaways From the McGuireWoods Independent Sponsor Conference

On Oct. 2-3, McGuireWoods hosted its second annual Independent Sponsor Conference in Dallas, attended by more than 600 independent sponsors and capital providers from more than 35 U.S. states and Canada. ...more

IRS Proposes Regulations on New Section 199A Passthrough Deduction

On August 8, the Internal Revenue Service (IRS) and the Department of the Treasury released proposed regulations on new section 199A, the 20 percent deduction for qualified business income, added to the Internal Revenue Code...more

Time to Update Your Partnership Agreement: New Rules Address Partnership Representatives for IRS Audits

Last week, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations concerning the designation and authority of a partnership representative under the centralized partnership audit regime...more

New Opportunities Follow Expansion of Section 45Q Carbon Sequestration Credits

The recent enactment of the Bipartisan Budget Act of 2018 extended and significantly expanded the existing tax credit for carbon sequestration under Section 45Q of the Internal Revenue Code. Although the Section 45Q credit...more

IRS Provides Solar ITC Guidance on the Begin-Construction Requirement

On June 22, the IRS issued Notice 2018-59, providing guidance to determine when construction has begun on energy facilities, for purposes of the Section 48 investment tax credit. The long-awaited guidance follows changes...more

2017 Tax Act’s Impact on Real Estate Companies and Their Owners

On Dec. 22, President Donald Trump signed into law the 2017 Tax Act, “An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018” (H.R. 1). This...more

Tax Reform Bill’s Impact on Renewable Energy Projects

On December 22, 2017, President Donald Trump signed into law the tax reform bill, “An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018” (H.R.1). The...more

Tax Reform Law’s Impact on Businesses and Their Owners

On Dec. 22, President Donald Trump signed into law the tax reform bill, “An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018” (H.R. 1). This...more

Qualified Disaster Relief Payments by Employers Not Taxable Income to Employees

Hurricane Harvey caused record-breaking devastation to Texas, followed quickly by Hurricane Irma, one of the strongest Atlantic storms in history, wreaking destruction in the southeastern United States. In the midst of these...more

IRS and Treasury Issue Regulations on “50(d) Income” Affecting Tax Credit Deals

The Internal Revenue Service and Department of Treasury recently issued final and temporary regulations on income inclusion under Section 50(d) of the Internal Revenue Code as it relates to the tax credit industry. The...more

Congress Passes Significant FIRPTA Reforms Affecting Foreign Investment in U.S. Real Estate - Protecting Americans from Tax Hikes...

On December 18, President Obama signed the Protecting Americans from Tax Hikes (PATH) Act of 2015 (the “Act”) into law. The Act, among other things, provides for substantial reforms to the Foreign Investment in Real Property...more

Congress Passes New Tax Laws Affecting REITs - Protecting Americans from Tax Hikes Act of 2015

On December 18, President Obama signed the Protecting Americans from Tax Hikes (PATH) Act of 2015 (the “Act”) into law. The Act provides for a number of favorable and flexible REIT-specific tax provisions, and implements...more

Congress Passes New Partnership Audit Rules - The Bipartisan Budget Act of 2015

On November 2, President Obama signed the Bipartisan Budget Act of 2015 into law, which brought sweeping changes to the partnership audit rules. The act repeals the substantive tax provisions and voluntary centralized audit...more

IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

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