Project Finance Blog
Tag or Topic: Renewable-energy
Subscribe to Renewable-energyIRS Rules on Late Solar Inverted Lease Elections
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
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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
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...
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Tax Court Levels Taxpayer's Weak Theories in Rent Accrual Case
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...
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Project Finance Developer Fees Explained
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.
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Missouri DOR Bungles Synthetic Lease
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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All Drywall Systems Aren’t Created Equal Under MACRS
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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IRS Blesses TRAC Lease Securitization
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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An Analysis of U.S. Energy Policy Objectives: Green and Brown Power Options Examined
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
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