Section 48 of the Internal Revenue Code of 1986, as amended (the “Code”) provides for an investment tax credit (“ITC”) for certain energy property. The Inflation Reduction Act of 2022 (the “IRA”) amended Section 48 in several...more
12/1/2023
/ Apprenticeships ,
Energy Projects ,
Energy Storage ,
Hydrogen Power ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Popular ,
Prevailing Wages ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Solar Energy ,
Tax Credits ,
U.S. Treasury
Developers of renewable energy projects prior to the Inflation Reduction Act of 2022 (the “IRA”) were able to enter into joint ventures and leasing arrangements with other private companies that had a sufficient tax liability...more
8/17/2023
/ Carbon Capture and Sequestration ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
Investors ,
IRS ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
On May 31, 2023, the IRS released Notice 2023-44 (the “Notice”) providing additional guidance on the advanced energy project tax credit (Section 48C), effectively reintroduced by the Inflation Reduction Act of 2022 (“IRA”). ...more
Managing Decommissioning Risks in Asian M&A Transactions -
By the end of 2026, approximately 134 producing Concessions and Production Sharing Contracts (each, a “PSC”) will have expired in South Asia. It is expected that 900...more
9/15/2017
/ Acquisitions ,
Asia ,
Cross-Border ,
Electricity ,
Force Majeure Clause ,
Greenhouse Gas Emissions ,
Hackers ,
IRS ,
Liquid Natural Gas ,
Mergers ,
Oil & Gas ,
Renewable Energy ,
Supply Chain ,
Take-or-Pay Contracts ,
Tax Reform
In Technical Advice Memorandum 2017-29-020 (July 21, 2017) (the “TAM”), the IRS denied claims by two tax equity investors (the “Investors” or each an “Investor”) for renewable energy tax credits on grounds that the...more