Engin Nural

Eversheds Sutherland (US) LLP

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IRS rules no violation of normalization requirements in computation of pro rata portion of ADIT used to reduce rate base

In a recent private letter ruling (PLR 201949006), the Internal Revenue Service (IRS) addressed the computation of the pro rata portion of accumulated deferred federal income tax reserve (ADFIT, together with the total...more

12/16/2019 / Accumulated Deferred Income Tax (ADIT) , Internal Revenue Code (IRC) , IRS , Private Letter Rulings , Public Utility , Tax Rates , Utility Rates

IRS clarifies the corrective measures a regulated transmission utility must undertake to avoid a normalization violation

In two recent private letter rulings (PLRs 201930015 and 201930016), the Internal Revenue Service (IRS) clarified the corrective measures a regulated transmission utility must undertake to avoid a normalization violation. In...more

8/1/2019 / FERC , IRS , Private Letter Rulings , Public Utility

IRS reaffirms that negotiated rates under PPA prevents solar facility from classification as “public utility property”

In Private Letter Ruling 201923019 (Feb. 21, 2019) (publicly released on June 10, 2019), the Internal Revenue Service (IRS) addressed a state statute that allowed a regulated public utility to acquire an unregulated solar...more

6/13/2019 / IRS , Power Purchase Agreements , Private Letter Rulings , Public Utility , Solar Farm , Utility Rates

IRS tells utility not to count its (deferred tax) chickens before they hatch

The affiliated group of which a taxpayer-utility was a wholly owned subsidiary filed tax returns on which it did not claim bonus depreciation since the availability of bonus depreciation had temporarily expired. Following the...more

10/25/2018 / Bonus Depreciation , Depreciation , IRS , Private Letter Rulings , Tax Rates , Utilities Sector

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