Philip Tingle on U.S. Treasury

The Domestic Content Bonus Credit’s Promising New Safe Harbor

On May 16, 2024, the Internal Revenue Service (IRS) published Notice 2024-41 (Notice), which modifies Notice 2023-38 (Prior Notice) by providing a new elective safe harbor (Safe Harbor) that will allow taxpayers to use...more

5/22/2024 / Economic Development , Energy Projects , Internal Revenue Code (IRC) , Investment Funds , Investors , IRS , Proposed Regulation , Safe Harbors , U.S. Treasury

Key Takeaways | Domestic Supply Chain, Manufacturing and the DPA: How America Will Step Back into Its Global Leadership Role

The Inflation Reduction Act of 2022 (IRA) is intended to stimulate domestic production in the US energy market and incentivize investment into those projects that utilize such domestic content. On October 26, Partners Carl...more

10/31/2022 / Energy Sector , Inflation Reduction Act (IRA) , Investment , Investors , Manufacturers , Onshoring , Production Tax Credit , Supply Chain , U.S. Treasury

Senate Democrats Propose Overhaul of Clean Energy Incentives

US Senate Finance Committee Chairman Ron Wyden (D-OR) introduced the Clean Energy for America Act (the Act), along with two dozen Democratic co-sponsors, on April 21, 2021. The Act will likely be a starting point for the...more

4/26/2021 / Biden Administration , Clean Energy , Environmental Protection Agency (EPA) , Investment Tax Credits , Production Tax Credit , Renewable Energy , Renewable Energy Incentives , Tax Credits , U.S. Treasury

IRS Releases Initial Section 45Q Carbon Sequestration Credit Guidance

Treasury and the IRS released initial guidance on the amended Section 45Q carbon oxide sequestration credit on February 19, 2020. Notice 2020-12 and Revenue Procedure 2020-12 provide guidance relating to the beginning of...more

2/21/2020 / Carbon Capture and Sequestration , Energy Projects , Investment Tax Credits , IRS , Production Tax Credit , Revenue Procedures , Safe Harbors , Tax Equity Partnership , U.S. Treasury

Alta Wind: Federal Circuit Reverses Trial Court and Kicks Case Back to Answer Primary Issue

On July 27, 2018, the US Court of Appeals for the Federal Circuit in Alta Wind v. United States, reversed and remanded what had been a resounding victory for renewable energy. The US Court of Federal Claims had ruled that the...more

8/7/2018 / 1603 Grants , Alta Wind Energy Center , American Recovery and Reinvestment Act , Power Purchase Agreements , Renewable Energy , U.S. Treasury

Act Now To Preserve Your Section 1603 Grant

In Depth - We recently reported that on October 31, 2016, the US Court of Federal Claims issued its opinion in Alta Wind I Owner v. United States, in which the court determined that the value of the property eligible for...more

11/15/2016 / 1603 Grants , Alta Wind Energy Center , American Recovery and Reinvestment Act , Arms Length Transactions , Court of Federal Claims , Damages , Energy Sector , Power Purchase Agreements , Renewable Energy , U.S. Treasury

Court Awards $206 Million to Alta Wind Projects in Section 1603 Grant Litigation; Smaller Award to Biomass Facility

The US Court of Federal Claims awarded damages of more than $206 million to Plaintiffs/applicants in a case with respect to the cash grant under Section 1603 of the American Recovery and Reinvestment Act of 2009 (Public Law...more

11/14/2016 / 1603 Grants , Alta Wind Energy Center , American Recovery and Reinvestment Act , Arms Length Transactions , Court of Federal Claims , Damages , Energy Sector , Power Purchase Agreements , Renewable Energy , U.S. Treasury

Court Awards $206 Million to Alta Wind Projects in Section 1603 Grant Litigation

The US Court of Federal Claims awarded damages of more than $206 million to the Plaintiffs in a case with respect to the cash grant program under Section 1603 of the American Recovery and Reinvestment Act of 2009 (the Section...more

11/7/2016 / 1603 Grants , Alta Wind Energy Center , American Recovery and Reinvestment Act , Arms Length Transactions , Damages , Power Purchase Agreements , Renewable Energy , U.S. Treasury

Final Regulations Define “Real Property” for REITs: Considerations for Renewable Energy and Transmission Assets

The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more

9/26/2016 / Income Taxes , Intangible Property , Internal Revenue Code (IRC) , Investment Trust Companies , IRS , Popular , Private Letter Rulings , REIT , Renewable Energy , U.S. Treasury

Philip Tingle

McDermott Will & Emery

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