Limits in Structured Finance Transactions
Many bankers and financial advisers may be wondering when they risk being charged with aiding in manipulating earnings in the wake of recent enforcement actions against three New York investment banks for acti
Depreciation Bonus Clarified
The Internal Revenue Service answered many questions that US companies had about when a “depreciation bonus” can be claimed on new power plants, transmission lines, LNG terminals, toll roads and o...
Hidden Pension Liabilities in Deals | Norton Rose Fulbright
Concern about giant potential liabilities tied to underfunded pension plans at some of America’s largest companies is spilling over into project sales in the power sector...
Found Money in Interconnection Agreements?
Generators and utilities are anxiously watching a complaint that Mirant filed with the Federal Energy Regulatory Commission asking the commission to revise a 2002 interconnection agreement with Ne...
When Power Plant Repairs Go Too Far
The US Environmental Protection Agency issued new rules in late August that draw a “bright line” for when planned repairs to a power plant or other industrial facility require an air permit before...
Help for Projects in Developing Countries
The World Bank is moving to make more useful and accessible a “partial risk guarantee program” under which it stands behind foreign government undertakings to sponsors of private infrastructure pr...
Tax Consequences from Discharging Debt
The Internal Revenue Service issued regulations in late August that clarify what happens when a corporation that is in bankruptcy is released from some of its debts...
Patents for Financing Structures
Some companies in the project finance market claim to have unique enough financing structures that they are moving to patent them...
Network Upgrades Controversy
A number of public utility companies and state public service commissions are pressing the Federal Energy Regulatory Commission to reconsider its policy of “socializing” the cost of grid improveme...
Environmental Update - October 2003
Combustion Turbines The US Environmental Protection Agency issued a final rule in late August that sets maximum achievable control technology, or “MACT,” standards for new and reconstructed statio...
Wind developers got more helpful rulings from the IRS | Norton Rose Fulbright
The IRS told one wind developer in a private ruling released in August that its wind farm would be considered “in service” for tax purposes, even though the wind farm was unable to move its full o...
Turbines that a power company ordered but no longer needs can sometimes be sold to a municipal utility without complications | Norton Rose Fulbright
TURBINES that a power company ordered but no longer needs can sometimes be sold to a municipal utility without complications, the IRS said. The key word is “sometimes...
Favorable financing terms are a separate asset, the US Tax Court said | Norton Rose Fulbright
FAVORABLE FINANCING TERMS are a separate asset, the US Tax Court said...
Synfuel plant owners are cautiously optimistic | Norton Rose Fulbright
SYNFUEL PLANT owners are cautiously optimistic...
Network upgrades remain under study at the IRS | Norton Rose Fulbright
NETWORK UPGRADES — or improvements to utility grids — remain under study at the IRS. A general ruling on which all utilities can rely is expected in the spring...
Repairs at power plants and other facilities are more likely to be deductible after a court decision in September | Norton Rose Fulbright
Repairs at power plants and other facilities are more likely to be deductible after a court decision in September...
Holland will have to allow some Dutch companies additional tax deductions | Norton Rose Fulbright
HOLLAND will have to allow some Dutch companies additional tax deductions, the European Court of Justice said in September...
Discharged debt did not have to be reported as income - Private Letter Ruling 200336032 | Norton Rose Fulbright
DISCHARGED DEBT did not have to be reported as income. Ordinarily when a company is released from a debt, it must report the amount discharged as taxable income...
Partnerships that do business in the US must withhold income taxes on US income that is allocated to any foreign partners | Norton Rose Fulbright
PARTNERSHIPS that do business in the United States must withhold income taxes on US income that is allocated to any foreign partners...
California expected to require broader registration of corporate tax shelter transactions | Norton Rose Fulbright
CALIFORNIA is expected to require broader registration of corporate tax shelter transactions starting next January 1...
States like Oregon are opening the door to corporate tax planning | Norton Rose Fulbright
STATES like Oregon are opening the door to corporate tax planning. Each state taxes companies doing business in the state only on income from sources inside the state...
Landfills that are listed as “Superfund” cleanup sites got bad news from a federal court | Norton Rose Fulbright
LANDFILLS that are listed as “Superfund” cleanup sites got bad news from a federal court in August...
Florida stamp taxes had to be paid on a property transfer because of poor planning | Norton Rose Fulbright
FLORIDA stamp taxes had to be paid on a property transfer because of poor planning. A limited partnership set up a limited liability company as a subsidiary and transferred land to it...
Phone companies won a property tax case in Florida and lost another in Wyoming | Norton Rose Fulbright
PHONE COMPANIES won a property tax case in Florida and lost another in Wyoming. The cases have implications for companies in other newly deregulated industries...
Dividends from foreign corporations qualify for a reduced US tax rate when received by individuals | Norton Rose Fulbright
DIVIDENDS from foreign corporations qualify for a reduced US tax rate when received by individuals...
A federal district court said that Black & Decker Corp. could not refuse an IRS demand for copies of tax planning communications | Norton Rose Fulbright
MINOR MEMO. A federal district court said that Black & Decker Corp...
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