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Guidance on Carbon Capture and Sequestration Tax Credit Provides Clarity for Developers and Investors

The Treasury Department and the Internal Revenue Service (IRS) recently released long-awaited proposed regulations regarding the carbon capture and sequestration tax credit provided under Section 45Q of the Internal Revenue...more

IRS Provides Relief for Renewable Energy Developers Encountering Construction Delays

The Internal Revenue Service (IRS) recently released Notice 2020-41 (the Notice), providing important relief with respect to the beginning-of-construction requirement for the production tax credit (PTC) and the investment tax...more

Amending a Debt Instrument Trading at a Discount: Beware of Tax Consequences

In light of the current economic uncertainty, many companies are considering amending their credit agreements and other debt instruments either to minimize the likelihood of breaching financial covenants or to rework payment...more

IRS Proposes New Section 382 Regulations To Further Limit Use of Tax Losses

On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more

"IRS Guidance Clarifies 'Begun Construction' Standard for Renewable Electricity Production Credit Property"

The Internal Revenue Service (IRS) has released welcome new guidance with respect to renewable electricity production and energy investment tax credits. A notice issued on May 5, 2016, reflects changes to the production tax...more

"Major Changes to Tax Audit Procedures to Impact Most Partnerships"

Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more

"Congress Extends Renewable Energy Tax Credits"

On December 18, 2015, President Barack Obama signed into law the Consolidated Appropriations Act, 2016 (Act), which extends and modifies the investment tax credit for solar energy property, the production tax credit for wind...more

"IRS Guidance Clarifies Renewable Energy Tax Credit"

The Internal Revenue Service (IRS) has released welcome new guidance on renewable electricity production and energy investment tax credits. A notice issued on August 8, 2014, addresses when a facility or equipment maintains...more

"IRS Guidance on the Commencement of Construction Requirements for Tax Credits for Qualified Energy Facilities"

On April 15, 2013, the Internal Revenue Service released Notice 2013-29 (Notice), which established guidelines and a safe harbor to determine when construction has begun on a “qualified facility” for purposes of the renewable...more

"Temporary ‘Fiscal Cliff’ Solution Yields Important Tax Changes"

On January 2, 2013, President Obama signed the American Taxpayer Relief Act of 2012 (the TRA of 2012), which permanently extends certain federal income tax rate reductions first enacted in 2001 that were scheduled to expire...more

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