Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more
On May 28, 2020, the IRS released proposed regulations under section 45Q (the “Proposed Regulations”) that had been widely anticipated since the expansion of the statute in 2018. The Proposed Regulations, which follow closely...more
In 2018, Congress revamped a tax credit available under section 45Q of the Internal Revenue Code (IRC) for companies that capture and sequester carbon dioxide (or other carbon oxides). On February 19, 2020, the Internal...more
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
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
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
The Internal Revenue Service (IRS) and the Federal Energy Regulatory Commission (FERC) have recently taken different approaches to issues raised by tax equity investors that have invested specifically in renewable energy...more
Revenue Procedure 2014-12 provides a safe harbor for historic tax credit (i.e., the Section 47 rehabilitation tax credit) partnership transactions. On January 8, the IRS issued a revised version of it that provides a...more
Tax credit investors received a big boost from the U.S. Tax Court in Historic Boardwalk Hall LLC v. Commissioner, 136 TC No. 1 (January 3, 2011). The court upheld a partnership structured to generate historic rehabilitation...more