On June 21, 2023, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published proposed regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA)...more
The Treasury Department and the Internal Revenue Service (IRS) recently released long-awaited proposed regulations regarding the carbon capture and sequestration tax credit provided under Section 45Q of the Internal Revenue...more
The Internal Revenue Service (IRS) recently released Notice 2020-41 (the Notice), providing important relief with respect to the beginning-of-construction requirement for the production tax credit (PTC) and the investment tax...more
5/29/2020
/ Begun Construction Test ,
Construction Project ,
Coronavirus/COVID-19 ,
Delays ,
Investment Tax Credits ,
IRS ,
Physical Work Test ,
Popular ,
Production Tax Credit ,
Relief Measures ,
Renewable Energy ,
Safe Harbors ,
Solar Energy ,
Wind Power
The question is no longer whether the volatility created by the COVID-19 pandemic will deepen the difficulties businesses and other institutions face in the coming months, but by how much and in what ways. In the past few...more
3/21/2020
/ Acquisitions ,
Antitrust Provisions ,
Audits ,
Board of Directors ,
Coronavirus/COVID-19 ,
Corporate Restructuring ,
Corporate Taxes ,
Court Closures ,
Debt-Equity ,
Energy Projects ,
Families First Coronavirus Response Act (FFCRA) ,
IRS ,
Liquidity ,
Mergers ,
Power Infrastructure ,
Securities Litigation ,
Shareholder Activism ,
Shareholder Meetings ,
Stock Repurchases
The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more
11/13/2018
/ Asset Valuations ,
C-Corporation ,
Capital Gains ,
Community Development ,
Investment Funds ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
QOZBP ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
RICs ,
S-Corporation ,
Startups ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
U.S. Treasury
The Internal Revenue Service (IRS) has released welcome new guidance with respect to renewable electricity production and energy investment tax credits. A notice issued on May 5, 2016, reflects changes to the production tax...more
On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more
11/5/2015
/ Administrative Procedure Act ,
Audits ,
Barack Obama ,
Bipartisan Budget ,
Burden of Proof ,
Business Taxes ,
C-Corporation ,
FPAA ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
K-1 ,
New Legislation ,
Partnership Interests ,
Partnerships ,
S-Corporation ,
Statute of Limitations ,
Tax Assessment ,
TEFRA ,
Treasury
The Internal Revenue Service (IRS) has released welcome new guidance on renewable electricity production and energy investment tax credits. A notice issued on August 8, 2014, addresses when a facility or equipment maintains...more
On April 15, 2013, the Internal Revenue Service released Notice 2013-29 (Notice), which established guidelines and a safe harbor to determine when construction has begun on a “qualified facility” for purposes of the renewable...more
Sponsors and investors have been paying much attention to the potential use of real estate investment trust (REIT) structures to hold and finance renewable energy assets in a tax-efficient way. A recent SEC filing by Hannon...more