On Oct. 31, the U.S. Internal Revenue Service (IRS) released Private Letter Ruling (PLR) 201444025, which was addressed to a manufacturer of solar...

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.

Posted in Renewable energy Blog article

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

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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

Posted in Wind Blog article

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

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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

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The Tax Court published an opinion that cautions taxpayers against being too innovative in their interpretation of this term of art.

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Climate change, energy independence, and health and welfare are policy rationales for alternate sources of electricity. Advances in technology have generated six choices for generating electricity: nuclear, coa

Posted in Renewable energy Solar Wind Blog article

Sophisticated investors have been investing in what are known as “tax equity flip partnership structures” for many years, predominately at first for wind farm investments. This article will explain in high-leve

As tax equity yields remain high and renewable energy is touted by the White House, the phone rings several times a month with the request to structure a fund that permits tax credits and...

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