News & Analysis as of

Renewable Energy Internal Revenue Code (IRC) 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

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

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

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

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