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Tax Credit Eligibility of Reflective Roofs to Bolster Solar Production
Tax Equity News
The “Right” way to Model the Timing of Recognition of ITC
June 02, 2016
Tax advisors working on investment tax credit (ITC) transactions are often asked what is the “right” way to model the timing of the recognition of the ITC benefit in an after-tax cash flow model.
Read MorePosted in Power Solar Blog article
Dominion Takes on Normalization Rules
IRS Rules on Late Solar Inverted Lease Elections
March 21, 2016
In two identical private letter rulings, LTR 201550024 and LTR 201550023, which were made public on December 11, the IRS granted a lessor in an inverted lease permission to make a late election to pass through
Read MorePosted in Blog article Renewable energy
Court of Federal Claims Fumbles Section 1603 Discovery Dispute
Tax Court Sheds Light on Counting Hours For the ‘Material Participation’ Exception to the Passive Activity Loss Rules
January 22, 2016
David Burton examines the Tax Court’s recent analysis in Leland v. Commissioner, favoring a lawyer’s bid for exception from the passive activity loss rules for his ‘‘material participation’’ of more than...
Read MorePosted in Renewable energy Blog article
Tax Court Levels Taxpayer's Weak Theories in Rent Accrual Case
September 28, 2015
The Tax Court’s recent decision in Stough v. Commissioner illustrates the traps for the unwary taxpayer in structuring commercial leases and the consequences of failing to review a tax return prepared by...
Read MorePosted in Blog article Wind Solar Renewable energy
IRS Private Letter Rulings Conflicted On Solar Tax Credits
December 15, 2014
On Oct. 31, the U.S. Internal Revenue Service (IRS) released Private Letter Ruling (PLR) 201444025, which was addressed to a manufacturer of solar...
Read MoreProject Finance Developer Fees Explained
November 25, 2014
In many renewable energy transactions, a ‘‘developer fee’’ is a critical feature—it is often the means by which the developer extracts its profits from months or years of work and risk.
Read MorePosted in Renewable energy Blog article
Missouri DOR Bungles Synthetic Lease
August 11, 2014
David Burton discusses a recent ruling from the Missouri Department of Revenue that is intended to address the sales tax consequences of a synthetic lease transaction. Burton argues that the DOR misapplied the
Read MorePosted in Renewable energy Blog article
