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BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

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As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more

Rivkin Radler LLP

Shared Appreciation Interest: Debtor-Creditor or Partners?

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When is a loan not a loan? When it’s something else – for example, equity. This is one of those pesky facts and circumstances issues that plague courts, taxpayers, and tax advisers to no end. Debt- On one end of the...more

Rivkin Radler LLP

Step Transaction Or Substance Over Form? Loss Disallowance In Any Case

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The Dog Days- I’ve never much cared for the month of August. In New York, at least for me, the eighth month of the year – named by the Roman Emperor, Augustus, to honor himself – evokes memories of very warm, very humid...more

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