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Project Finance Internal Revenue Service

Venable LLP

IRS Ruling Provides Insights on Compensation Options for Managers of Tax-Exempt Bond-Financed Hotels, CCRCS and Similar Facilities

Venable LLP on

​​​​​​​Facilities owned by nonprofits and government entities are frequently financed with tax-exempt bonds and managed by for-profit management companies. To avoid tainting the tax-exempt status of the interest payable on...more

Eversheds Sutherland (US) LLP

IRS extends continuity safe harbor for renewable energy projects

On June 29, 2021, the IRS issued Notice 2021-41, which provides a further extension of the continuity safe harbor and revises the “facts and circumstances” rules: ..For PTC and ITC-eligible projects for which...more

Cozen O'Connor

Invested Sinking Funds Revisited: A Cautionary Reminder for Issuers and Borrowers

Cozen O'Connor on

In 1978, responding to attempts by issuers and borrowers to set aside funds for investment above the yield on outstanding tax-exempt bonds, the IRS published regulations seeking to shut down the practice of establishing...more

Cozen O'Connor

IRS Updates, Modernizes and Simplifies TEFRA Public Notice and Approval Regulations

Cozen O'Connor on

Final TEFRA regulations issued by the IRS were published in the Federal Register on December 31, 2018. They apply to qualified private activity bonds (e.g., qualified 501(c)(3) bonds and exempt facility bonds) issued pursuant...more

Orrick, Herrington & Sutcliffe LLP

Bottled Booze in the Boarding Area IRS Ruling Permits Use of Floating Equity in Airport Exempt Facility Private Activity Bond...

In a recently released private letter ruling (Private Letter Ruling 201847001, or the “Ruling”), the IRS approved the use of a “floating equity” allocation method for exempt facility bonds issued to finance renovations to an...more

Nossaman LLP

P3 Industry Gets An Early Holiday Present In IRS Guidance On Interest Deduction

Nossaman LLP on

Contractors and investors in P3s can continue taking a full tax deduction for interest on debt under recent IRS guidance (Revenue Procedure 2018-59, issued November 26). ...more

Akin Gump Strauss Hauer & Feld LLP

Solar Start of Constructive Guidance, a Comprehensive Analysis

New Internal Revenue Service (IRS) guidance on what it takes to start construction of a solar project raises practical questions, but it is very helpful in keeping the industry humming along. Solar projects that are under...more

Akin Gump Strauss Hauer & Feld LLP

US Solar Structures: Cash Equity Considerations

The solar financing market is maturing. You can tell because new money is crowding into the market, and the capital stacks are getting more complicated. Many of these funky structures even have names, like the “Double...more

Ballard Spahr LLP

New IRS Management Guidance is Flexible, Furthers P3s

Ballard Spahr LLP on

State and local governments and 501(c)(3) organizations have been given very flexible guidance by the IRS for longer-term private management of tax-exempt bond financed projects to facilitate general operations and major...more

Akin Gump Strauss Hauer & Feld LLP

Tax Equity Structuring, Financial Modeling and HLBV Accounting

Akin Gump partner, David Burton and Alfa Business Advisors director, Vadim Ovchinnikov hosted a seminar on Tax Equity Structuring, Financial Modeling and HLBV Accounting yesterday. The seminar covered a variety of topics...more

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