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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

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

S.D.N.Y. Judge Permits Novel Theory And Allows SEC To Use Unpaid Taxes As Measure Of Disgorgement In Securities Fraud Case

In a case against Dallas billionaires Sam Wyly and the estate of his late brother, Charles, Judge Shira Scheindlin of the U.S. District Court for the Southern District of New York agreed with the U.S. Securities and Exchange...more

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