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IRS Releases Preliminary Guidance on the IRA Domestic Content Bonus Credit

On May 12, 2023, the Internal Revenue Service (IRS) released long-awaited guidance on the domestic content bonus credit under the Inflation Reduction Act of 2022 (IRA). Specifically, the IRS released Notice 2023-38 regarding...more

Federal Circuit Reverses and Remands Alta Wind Case Holding that a Portion of the Asserted Section 1603 Basis May be Allocable to...

In a case decided on July 27, 2018, the U.S. Court of Appeals for the Federal Circuit (the Court of Appeals) reversed the Court of Federal Claims' (the Claims Court) decision in Alta Wind I Owner-Lessor C et al v. United...more

IRS Issues Notice 2018-59: "Begun Construction" Guidance for the Investment Tax Credit

On June 22, 2018, the IRS issued Notice 2018-59 (ITC Guidance), providing long-awaited guidance on the "begun construction" requirements for facilities qualifying for the Section 48 investment tax credit (ITC). The ITC is a...more

Senate Finance Committee Releases Its Version of the Tax Cuts and Jobs Act

After releasing summaries and various Chairman's marks, the Senate Finance Committee ("SFC") approved its tax reform bill, the "Tax Cuts and Jobs Act," on November 16, 2017 and released the legislative text of the bill to the...more

House Committee on Ways and Means Releases Tax Cuts and Jobs Act

On November 2, 2017, the House Committee on Ways and Means, led by Republican Chairman Kevin Brady, released H.R. 1, the "Tax Cuts and Jobs Act." The House Committee is expected to mark up the bill beginning on November 6,...more

President Trump Issues Executive Order on Climate Change

On March 28, 2017, President Donald Trump issued an executive order that significantly rolls back climate change policy enacted under the Obama administration and requires review of agency actions that may negatively impact...more

IRS Provides an ITC Safe Harbor for Projects Under Energy Savings Performance Contract Energy Sales Agreements with Release of...

On January 19, 2017, the IRS released an advance version of Revenue Procedure 2017-19, which provides a safe harbor (the "Safe Harbor") under which the IRS will not challenge the treatment of an Energy Savings Performance...more

IRS Issues Proposed Regulations on Centralized Partnership Audit Regime

On January 18, 2017, the IRS released proposed regulations (the "Proposed Regulations") to implement Section 1101 of the Bipartisan Budget Act of 2015 (BBA),1 which replaces the current rules governing partnership...more

IRS Issues Notice 2017-04, Further Clarifying and Extending the "Begun Construction" Requirements for ITCs and PTCs

On December 15, 2016, the IRS issued Notice 2017-04, which clarifies and extends certain "begun construction" requirements for facilities qualifying for the Section 45 production tax credit (PTC) for which construction must...more

The Unwind: ‘I Don’t Want It’

In the inaugural column of ‘‘Power and Taxes,’’ we discussed the tensions surrounding the requirement that an investor be an owner when a project is placed in service in order to qualify for the investment tax credit under...more

Final IRS Regulations Clarify That Certain Solar Assets May Qualify as Real Property for REIT Purposes

On August 30, 2016, the IRS issued final regulations that clarify and expand the definition of "real property" for purposes of qualifying as a real estate investment trust (REIT). The final regulations substantially follow...more

IRS Releases Temporary and Proposed Regulations Under IRC Section 50(d)(5)

On July 21, 2016, the IRS released temporary regulations section 1.50-1T under IRC Section 50(d)(5) of the Internal Revenue Code (the "Temporary Regulations") (TD 9776) that provide guidance regarding: (1) the income...more

After Extension, IRS Clarifies "Begun Construction" Guidance for PTCs

Following last year's extension of the investment tax credit for qualifying projects for which construction begins prior to January 1, 2020, and of the production tax credit (PTC) with respect to certain facilities the...more

Tax Extenders Signed into Law; Solar and Wind Tax Credits Extended

Earlier today, President Obama signed the Military Construction and Veterans Affairs and Related Agencies Appropriations Act, 2016 (the Act)—which includes the Consolidated Appropriations Act of 2016 and the Protecting...more

President Obama Signs Bipartisan Budget Act of 2015

On November 2, 2015, President Obama signed into law the "Bipartisan Budget Act of 2015" (P.L. 114-74). Among other things, the act eliminates the TEFRA unified partnership rules and the electing large partnership rules, and...more

11/6/2015  /  Audits , Federal Budget , IRS , Partnerships , TEFRA

IRS Extends "Begun Construction" Guidance

Earlier yesterday, the IRS released Notice 2015-25, 2015-13 IRB 1, which updates the guidance provided in Notice 2013-29, 2013-1 C.B. 1085, Notice 2013-60, 2013-2 C.B. 431, and Notice 2014-46, 2014-36 I.R.B. 520...more

Tax Extenders Signed into Law; Production Tax Credit Extended for Facilities Beginning Construction in 2014

Earlier today, President Obama signed the Tax Increase Prevention Act of 2014 (H.R. 5771) into law, following its passage through Congress on Tuesday. Among other things, the act will provide a one-year retroactive extension...more

IRS Clarifies "Begun Construction" Guidance

On August 8, 2014, the Internal Revenue Service (IRS) issued Notice 2014-46, which clarifies and modifies Notice 2013-29 and Notice 2013-60....more

8/12/2014

Proposed IRS Regulations Would Qualify PV Modules as Real Property under REIT Rules in Certain Circumstances

On May 9, 2014, the Internal Revenue Service (IRS) issued proposed regulations that clarify the definition of real property for purposes of the real estate investment trust (REIT) provisions of the Internal Revenue Code....more

5/13/2014  /  Energy Projects , IRS , REIT , Solar Energy
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