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Court of Federal Claims Fumbles Section 1603 Discovery Dispute
Tax Equity News
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
How Wind Developers Raise Equity In Public Markets
May 31, 2014
Many wind developers regularly require additional capital infusion and keep their eyes peeled for opportunities to raise it. Three recent trends in public equity transactions for developers are yieldcos, listin
Read MorePosted in Wind Blog article
All Drywall Systems Aren’t Created Equal Under MACRS
May 15, 2014
David Burton examines a recent private letter ruling where the Internal Revenue Service held that ‘‘zip’’ drywall partition systems are depreciated faster than conventional drywall partitions. He compares the S
Read MorePosted in Renewable energy Blog article
IRS Blesses TRAC Lease Securitization
February 24, 2014
In Private Letter Ruling 201404007, released Jan. 24, the Internal Revenue Service ruled favorably on a securitization structure to raise nonrecourse financing secured by cars subject to leases with a terminal
Read MorePosted in Renewable energy Blog article
Salesman Penalized for ‘Placed in Service' Interpretation
February 17, 2014
The Tax Court published an opinion that cautions taxpayers against being too innovative in their interpretation of this term of art.
Read MorePosted in Blog article Infrastructure
