New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations.
As previously discussed, the 2017 Tax Cuts...more
3/8/2018
/ Asset Management ,
Business Assets ,
Business Taxes ,
C-Corporation ,
Capital Gains ,
Carried Interest ,
Fund Managers ,
Investors ,
IRS ,
Limited Liability Company (LLC) ,
Partnership Interests ,
S-Corporation ,
Tax Cuts and Jobs Act
The 2017 Tax Cuts and Jobs Act (the Act), signed by President Trump last month, significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest....more
The tax reform bill, commonly referred to as the Tax Cuts and Jobs Act of 2017 (the Act), was signed into law on December 22, 2017. The Act contains a number of provisions that create significant year-end planning...more
12/28/2017
/ Acquisitions ,
Bonus Depreciation ,
Corporate Taxes ,
Mergers ,
Net Operating Losses ,
Pass-Through Entities ,
Stock Options ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
The IRS recently issued Notice 2016-31, providing further guidance regarding the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the Internal Revenue Code and the investment tax...more
5/16/2016
/ Biomass ,
Energy Projects ,
Energy Sector ,
Geothermal Energy ,
Hydropower ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Protecting Americans from Tax Hikes (PATH) Act ,
Qualified Energy Facilities ,
Renewable Energy ,
Renewable Energy Incentives ,
Safe Harbors ,
Solar Energy ,
Wind Power
The renewable energy industry, particularly the wind and solar energy sectors, have been hopeful that the U.S. Congress would act this year to extend certain tax credits that project developers and related sectors, such as...more
Recently, the Internal Revenue Service issued final regulations addressing reorganizations, commonly referred to as “F reorganizations,” under Section 368(a)(1)(F) of the Internal Revenue Code (the Code). F reorganizations...more
On September 4, 2015, the Internal Revenue Service released a private letter ruling that could have meaningful impacts on the funding and development of certain residential solar developments, specifically community solar...more
The Internal Revenue Service recently issued the expected Notice 2015-25, which supplements its earlier notices on the same subject and provides additional guidance to renewable energy facility developers and investors when...more