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Impact of the House Tax Reform Bill on the Renewable Energy Sector

Bold proposal seeks changes to tax credits, depreciation, and corporate tax rates. Key Points: - Production Tax Credits are cut by more than one-third. - Bill may impact existing and future tax equity...more

IRS Issues Welcome Guidance on “Continuity Safe Harbor” for Wind Energy Projects

New rules provide wind developers with additional time to satisfy a critical safe harbor. On December 15, 2016, the Internal Revenue Service (IRS) issued Notice 2017-4, which modifies the “continuity safe harbor” as set...more

Alta Wind Wins Cash Grant Dispute in Court of Federal Claims – Awarded US$206 Million

Favorable decision clarifies the value of cash grants and investment tax credits for renewable energy projects. A large wind developer won a significant victory in the Court of Federal Claims on October 28 in a case that...more

IRS Tightens Rules on Disguised Sales and Allocating Partnership Liabilities

New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions. On October 4, 2016, the Internal Revenue Service (IRS)...more

IRS Issues Additional Guidance on “Begun Construction” Requirement for Wind Energy Credits

Latest guidance extends “continuity safe harbor” to four years and includes other taxpayer-friendly modifications and clarifications to existing guidance. On May 5, 2016, the Internal Revenue Service (IRS) issued...more

New Long-Term Extension of Wind and Solar Tax Credits Subject to Phase-out

Congress extends tax credits for wind and solar energy projects, but will phase the credits out over several years. The Consolidated Appropriations Act, 2016 (the Act), which President Obama signed into law on December...more

New Tax Audit Regime Constitutes a Sea Change for Partnerships

Legislation impacts tiered partnerships and M&A transactions. Existing partnerships should review operating agreements before new rules take effect. The Bipartisan Budget Act of 2015 (the Act), which President Obama...more

11/9/2015  /  Audits , IRS , K-1 , Partnerships , TEFRA

IRS Proposes Significant Changes to Rules for Allocating Partnership Liabilities

Proposed Regulations seek to curtail perceived abuses, including the use of “bottom-dollar” guarantees and some indemnity arrangements. On January 29, 2014, the Internal Revenue Service (IRS) proposed regulations that...more

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