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

Posted in Blog article Renewable energy

Posted in Renewable energy Wind Blog article

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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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...

Posted in Blog article Wind Solar Renewable energy

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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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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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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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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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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