News & Analysis as of

Production Tax Credit Revenue Procedures

McDermott Will & Emery

Weekly IRS Roundup November 21 – November 25, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 21, 2022 – November 25, 2022...more

Mintz - Energy & Sustainability Viewpoints

Viewing Notice 2020-12 Through the Lens of Notice 2013-29 and Notice 2018-59: How is “Beginning of Construction” Guidance for...

In February 2020, the IRS issued Notice 2020-12, which provides long-awaited guidance on when a “qualified facility” or carbon capture equipment, in each case within the meaning of section 45Q, is considered to have “begun...more

Mintz - Energy & Sustainability Viewpoints

Revisiting Rev. Proc. 2007-65 via Rev. Proc. 2020-12: What Can the Carbon Capture Credit Guidance Tell Us About Wind Partnership...

Earlier in the year, the IRS released Revenue Procedure 2020-12, which establishes a safe harbor for the allocation of section 45Q credits in so-called “partnership flip structures” and the equity treatment of tax equity...more

Morgan Lewis

IRS Releases Critical Guidance on Carbon Capture Tax Credits

Morgan Lewis on

The guidance issued on February 19 by the Internal Revenue Service is the type that the carbon capture and storage industry had sought, and will hopefully open up the market for investment by eliminating tax-related...more

McDermott Will & Emery

IRS Releases Initial Section 45Q Carbon Sequestration Credit Guidance

McDermott Will & Emery on

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

McDermott Will & Emery

IRS Issues Private Letter Ruling Allowing Tax Equity Financing with a Regulated Utility Taxpayer

McDermott Will & Emery on

In Private Letter Ruling 201946007, the Internal Revenue Service (IRS) allowed a tax equity investor to participate with a regulated utility in a tax equity financing arrangement for wind investments without being subject to...more

Eversheds Sutherland (US) LLP

IRS releases 2018 section 45 production tax credit amounts

The Internal Revenue Service (IRS) recently published Revenue Procedure 2018-50, which provides the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy production tax credits...more

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