Seth Eaton Discusses Modifications and Workouts of Commercial Real Estate Loans during the COVID-19 Pandemic
Im Schneckentempo zur Energiewende - Ende August hat das Bundesministerium der Finanzen einen Referentenentwurf für ein Zweites Gesetz zur Finanzierung von zukunftssichernden Investitionen (ZuFinG II) vorgelegt. Die...more
Dechert LLP recently obtained an IRS private letter ruling (“PLR”) on behalf of an asset manager concluding that certain C-PACE assessments are “obligations . . . secured by an interest in real property” for purposes of the...more
On April 25, 2024, the Department of the Treasury and the Internal Revenue Service issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for certain tax credits by eligible...more
On April 16, 2024, Ameek Ashok Ponda, with assistance from Paul Decker, Sarah Wellings and Connie Lee, submitted a comment letter to the Internal Revenue Service (IRS) regarding his recommendations for the 2024-2025 Priority...more
When Treasury promulgated Treasury Decision 9784, I.R.B 2016-39 nearly a decade ago, the net metering renewable energy safe harbor (Section XI “Renewable Energy”, Subsection A) was welcome guidance that was fit for the time...more
On June 14, 2023, the Internal Revenue Service and the Treasury Department issued (among other guidance) an expansive set of proposed regulations explaining how taxpayers can monetize 11 green energy tax credits through...more
On August 16th, President Biden signed the Inflation Reduction Act of 2022 (H.R. 5376) into law (the “IRA”). Among the most significant provisions in the bill are extensions and expansions of clean energy tax incentives, a...more
The Inflation Reduction Act of 2022 (the “IRA”), which was signed into law on Tuesday, August 16, 2022, includes an investment of over $369 billion in energy security and climate change. There has been a lot of discussion...more
While the market witnessed a flurry of renewable energy and clean tech IPOs from 2010-2015, they have become much rarer in recent years despite markedly improved market fundamentals. In this article, we highlight current...more
The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more
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
Sustainable Development Focus - REIT reporting standards for sustainability lack consensus REIT.com - Jul 29 - There are roughly a dozen or so real estate sustainability standards competing for the attention...more
Since the first wind deal utilizing a partnership in 2003 (also known as a “partnership flip,” a “pre-tax after-tax partnership,” or a “wind safe harbor partnership structure”), there has been a constant evolution of...more
In our post on August 19, “Yieldcos – The New “Promised Land” of the Renewable Energy Space?”, we explored the Yieldco structure and why some renewable energy companies are considering them. We will now turn our attention to...more
The IRS has opened the door a crack for real estate investment trusts (REITs) to be the lessors of wind projects. To qualify as a REIT, a corporation must satisfy a series of complicated tests that require the...more
The Internal Revenue Service and the U.S. Department of the Treasury recently issued proposed regulations that may facilitate using real estate investment trusts (REITs) as vehicles for financing certain renewable energy...more
The modified “flow-through” tax treatment afforded to REITs depends on the entity’s ability to meet certain asset and income-based tests, all of which in turn key off of the definition of “real estate.” ...more
President Obama announced on Friday several executive actions to advance clean energy. Among them, the Internal Revenue Service (IRS) will publish new regulations on May 14th clarifying that certain solar generating assets...more
Sponsors and investors have been paying much attention to the potential use of real estate investment trust (REIT) structures to hold and finance renewable energy assets in a tax-efficient way. A recent SEC filing by Hannon...more
In This Issue: Renewable Energy Focus - Solar installations to grow more than 18 percent yearly through 2020; Solar REITs May Power the Industry Forward; U.S. Geothermal Inc. reports its development goals for 2013;...more
In the January edition of Energy & Clean Tech Connections, we’ve gathered recent information from a wide variety of sources in an effort to keep you abreast of what’s new in the world of clean energy. We draw your attention...more