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Tax Reform Bill Released

Republican leaders yesterday released their comprehensive tax reform bill, the “Tax Cuts and Jobs Act.” Although there has been a great deal of high-level discussion over the past few months regarding various tax reform...more

Tax Reform Bill Limits Renewable Energy Credits

The much anticipated tax reform bill released today by the Republican leadership in the House would make several potentially significant changes to certain energy tax provisions. These would include changes to the Production...more

Tax Law Alert: “Big Six” Release Tax Reform Framework Supported by President Trump

After months of speculation a group of Republican leaders referred to as the “Big Six” (House Speaker Paul Ryan, Senate Majority Leader Mitch McConnell, House Ways and Means Committee Chairman Kevin Brady, Senate Finance...more

IRS Updates “Beginning of Construction” Guidance

The IRS today issued highly anticipated guidance updating the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the Internal Revenue Code (the Code) and the investment tax credit...more

Energy Tax Law Alert: IRS Expands Safe Harbor for Transfers of Property to Transmission Providers

The IRS on June 10 issued Notice 2016-36, which expands a safe harbor allowing certain transfers of property to regulated public utilities to be treated as nontaxable contributions of capital to a corporation, rather than as...more

Energy Tax Law Alert: IRS Rules That Payment for Intertie Constitutes Taxable Contribution in Aid of Construction

The IRS has issued a private letter ruling concluding that the reimbursement by a solar electric generator of an electric distribution company’s costs to construct an intertie is a contribution in aid of construction under...more

Energy Tax Law Alert: IRS Updates "Beginning of Construction" Guidance

The IRS has issued highly anticipated guidance updating the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the Internal Revenue Code (the Code) and the investment tax credit...more

Renewable Energy Tax Credits Receive Multiyear Extension in Congressional Omnibus Bill

Congressional leadership reached agreement late last evening on an omnibus spending and tax bill that will be voted on by the House and Senate later this week. The bill reflects a global agreement among the leaders on tax and...more

Energy Tax Law Alert: IRS Updates "Beginning of Construction" Guidance

The IRS today issued Notice 2015-25, updating its prior guidance in Notices 2013-29, 2013-60, and 2014-46, regarding the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the...more

Energy Tax Alert: Congress Extends Biofuel Incentives

Congress this week passed the Tax Increase Prevention Act of 2014, which extends a number of expired or expiring tax provisions through the end of 2014. The President is expected to sign the Act soon. The Act extends a number...more

Tax Law Alert: The Tax Increase Prevention Act of 2014 Extends Expired or Expiring Provisions

Congress this week passed the Tax Increase Prevention Act of 2014 (the Act), which is expected to be signed by President Obama at any time. The Act renews or extends a number of expired or expiring provisions. Some of the...more

Energy Tax Alert: Congress Extends Renewable Energy Credits

Congress this week passed the Tax Increase Prevention Act of 2014, which extends a number of expired or expiring tax provisions through the end of 2014. The President is expected to sign the Act soon. The Act renews several...more

Energy Tax Law Alert: IRS Issues New Guidance Regarding Beginning of Construction Requirement for ITC/PTC

On Friday, the IRS issued guidance that clarifies and modifies prior guidance regarding the “beginning of construction” requirement for qualifying for the production tax credit (PTC) under Section 45 of the Internal Revenue...more

Proposed Regulations Address REIT Investments in Solar Facilities

The Internal Revenue Service and the U.S. Department of the Treasury recently issued proposed regulations that may facilitate using real estate investment trusts (REITs) as vehicles for financing certain renewable energy...more

Biofuels Law Alert: IRS Addresses the Identity of the "Producer" in Contract Manufacturing Arrangements

Last week the IRS released an internal memorandum addressing which of the parties to a contract manufacturing arrangement for biodiesel is treated as the “producer” of the biodiesel for certain federal tax purposes....more

Energy Tax Law Alert: IRS Clarifies "Beginning of Construction" Guidance

On September 20th, the IRS issued Notice 2013-60, which updates prior guidance, contained in Notice 2013-90, regarding the "begin-construction" requirement for the production tax credit (PTC) under Section 45 of the Internal...more

IRS Likely to Supplement "Beginning Construction" Guidance

As most of you are aware, Congress in the "American Taxpayer Relief Act of 2012" eliminated the "placed in service" deadline for purposes of the renewable energy tax credits. In its place, Congress required for purposes of...more

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