On June 14, 2023, the IRS and Treasury Department released proposed regulations regarding the monetization of certain clean energy tax credits, as well as temporary regulations regarding mandatory information and registration...more
The IRS plans to audit the wealthiest corporate, partnership, and individual taxpayers to achieve some of its main objectives in 2022.
In his recent testimony before Congress, IRS Commissioner Charles P. Rettig...more
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
According to NAREIT, “real estate investment trusts,” or REITs, own more than $3 trillion of U.S. real estate assets. With REITs having survived (and, in some respects, thrived) under recent tax reform, that number likely...more
The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more
6/21/2017
/ Audits ,
Bipartisan Budget Act ,
IRS ,
Limited Liability Company (LLC) ,
Local Taxes ,
Partnerships ,
Proposed Regulation ,
Regulatory Freeze ,
TEFRA ,
Trump Administration ,
UPREITS
On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more
10/25/2016
/ Business Taxes ,
Debt Financing ,
Disguised Sales ,
IRS ,
New Regulations ,
Partnership Agreements ,
Partnership Liabilities ,
Partnerships ,
Proposed Regulation ,
Risk Allocation ,
U.S. Treasury
On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more
10/24/2016
/ Credit Agreements ,
Creditors ,
Debt Instruments ,
Debt-Equity ,
Debtor-Creditor ,
Disregarded Entities ,
Enforcement ,
Expanded Group Instruments (EGIs) ,
IRS ,
Proposed Regulation ,
Rebuttable Presumptions
On August 31, 2016, the Treasury Department published final regulations (the “Final Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The Final Regulations...more
9/15/2016
/ Crops ,
Data Centers ,
Final Rules ,
Intangible Property ,
IRS ,
Pipelines ,
Private Letter Rulings ,
Proposed Regulation ,
REIT ,
Solar Farm ,
U.S. Treasury
On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law. Among the numerous changes in tax law contained in the Act are five-year extensions of the 30% investment tax credit (“ITC”),...more
On May 14, 2014, the Treasury Department published proposed regulations (the “Proposed Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The issuance of the...more