News & Analysis as of

Renewable Energy Private Letter Rulings

Cadwalader, Wickersham & Taft LLP

IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions

The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more

Holland & Knight LLP

Eyes on Energy Tax Update: Third Quarter 2023

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Eyes on Energy Tax Update is a regular publication of the Holland & Knight Renewable and Alternative Energy Tax Team that provides highlights of important developments. The Renewable and Alternative Energy Tax Team also...more

Holland & Knight LLP

Eyes on Energy Tax Update: First Quarter 2023

Holland & Knight LLP on

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. ...more

Holland & Knight LLP

Eyes on Energy Tax Update: January 2023

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Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. The fourth quarter of 2022 brought a flurry of energy tax...more

Eversheds Sutherland (US) LLP

Green Tax - Volume 1

Welcome to Green Tax, Vol. 1. Each quarter we will provide a recap of some of the important energy tax issues of the last quarter, including court rulings, IRS rulings and guidance, legislative activity, and more....more

Sheppard Mullin Richter & Hampton LLP

Tax Equity for Public Utilities

In light of a recent IRS Private Letter Ruling addressing public utility property and loss disallowance rules, here are six key items to be aware of today in tax equity transactions for renewable energy projects owned by...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

Mayer Brown

Residential Solar Storage is Eligible for Tax Credit, Subject to a 100% Cliff

Mayer Brown on

In a recently released private letter ruling, the IRS confirmed that residential solar energy batteries are eligible for the tax credit under Section 25D of the Code (the “Residential Solar Credit”), subject to an important...more

McDermott Will & Emery

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

McDermott Will & Emery on

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

Foley & Lardner LLP

IRS Releases Favorable Guidance for Individual Investors in Community Solar to Claim Section 25D Tax Credit

Foley & Lardner LLP on

The IRS recently issued a Private Letter Ruling (PLR) clarifying that an individual investor in a net-metered community solar project may claim the federal residential Investment Tax Credit (ITC) under Section 25D of the...more

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