The U.S. Department of the Treasury (Treasury) earlier this week issued two notices of proposed rulemaking (the Proposed Regulations) related to the election to transfer certain tax credits (the Tax Credit Transfer Election)...more
The United States Court of Federal Claims recently released two anticipated opinions, Bishop Hill Energy, LLC v. United States and California Ridge Wind Energy, LLC v. United States, which were issued under seal on January 7,...more
6/26/2019
/ 1603 Grants ,
Burden of Proof ,
Counterclaims ,
Department of Justice (DOJ) ,
Economic Substance Doctrine ,
Energy Projects ,
Fees ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
Renewable Energy ,
Sham Transactions ,
Tax Credits ,
Testimony
The Treasury Department issued proposed regulations related to qualified opportunity zones on October 19, 2018. Congress created the qualified opportunity zone regime as part of the Tax Cuts and Jobs Act, which was enacted at...more
The IRS today issued guidance regarding the “beginning of construction” requirement as it related to the investment tax credit (ITC) under Internal Revenue Code Section 48. The guidance, Notice 2018-59, generally applies the...more
The ability to defer taxes through a 1031 Exchange can make or break a real estate transaction. But federal tax law does not treat all real estate owners equally. Under IRC Section 1031(a)(2), real property held “primarily...more
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
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
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
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
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
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
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