Good news came for renewable energy developers on June 29, 2021, when the IRS issued Notice 2021-41. The notice gives developers more time to finish projects and makes it easier to prove that they began construction on a...more
The rapidly growing offshore wind sector received a significant boost at the end of 2020, thanks to the creation of a new investment tax credit (“ITC”) for offshore wind projects and the issuance of an IRS notice extending...more
On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section 956 of the Internal Revenue Code (the “Code”) in an attempt to align it...more
On September 5, 2014, the Internal Revenue Service (“IRS”) released Private Letter Ruling 201436001 (the “Ruling”), which found that a company providing products and services primarily within the pharmaceutical industry was a...more
On January 29, 2014, the Internal Revenue Service (“IRS”) and the Treasury Department issued proposed regulations (the “Proposed Regulations”) modifying the rules under Section 752 regarding the allocation of recourse and...more