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Tax Deferral Utilities Sector

Holland & Knight LLP

IRS Rules 3 Utilities Cannot Reduce NOL Carryforwards for Tax Allocation Payments

Holland & Knight LLP on

Following the initial public release of private letter ruling (PLR) 20242002 as part of a state rate proceeding, on June 28, 2024, the IRS publicly released that ruling, as well as two companion rulings obtained by other...more

Eversheds Sutherland (US) LLP

PLR on the normalization of cost of removal and accounting method changes for repairs and mixed service costs, but questions...

On August, 15, 2020, the Internal Revenue Service (IRS) issued PLR 202033002, in which it addressed whether cost of removal (COR) is “protected” by the normalization rules of section 168(i)(9). COR is often embedded in a...more

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