Publications

New US tax rules could reclassify debt as equity

Keith Martin
April 12, 2016

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Topics IRS, earnings stripping, shareholder loans, debt-equity, Section 385, corporate inversions

Additional Construction-Start Guidance

Keith Martin
August 21, 2014

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Topics Start Construction, IRS, physical work, Notice 2014-46

Prepaid Power Contracts

Keith Martin
September 1, 2012

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Topics IRS, prepaid PPA, inventoriable goods, electricity, prepayment, section 451, deferred income, deferral

Developer Fees

Keith Martin
March 31, 2011

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Topics Renewable Energy, IRS, solar projects, Basis step-up, Development fee, Developer fee

IRS Addresses Interconnection Payments

Keith Martin
August 1, 2005

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Topics FERC, IRS, Utility, Grid, Interconnection, independent generator, transmission credits, network upgrade, tax treatment

“Dash Six Liability” Problems In Deals

Keith Martin
August 1, 2003

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Topics M&A, IRS, tax, Acquisitions, 1.1502-6, consolidated returns, dash six liability
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