David Burton
April 16, 2018
In its Finance Quarterly, A Word About Wind has published a brief Q&A between David Burton and its editor Richard Heap. The Q&A touches on a variety of is
Q&A with A Word About Wind
The Dramatic Arc of the PTC
David Burton
October 2, 2017
My article The Dramatic Arc of the PTC was just published in North American WindPower and discusses the history of the production tax credit (PTC) from it
Tax Credit Eligibility of Reflective Roofs to Bolster Solar Production
David Burton
August 1, 2016
Below is a link to my Tax Notes article that discusses three IRS letter rulings involving the investment tax credit eligibility of reflective roofs that bo
The “Right” way to Model the Timing of Recognition of ITC
David Burton
June 2, 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
Dominion Takes on Normalization Rules
David Burton
April 2, 2016
Testimony on Feb. 23 to Virginia’s State Corporate Commission from an advisor to the commission described the strategy of Dominion’s Virginia Electric and
IRS Rules on Late Solar Inverted Lease Elections
David Burton
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 le
Court of Federal Claims Fumbles Section 1603 Discovery Dispute
David Burton
February 19, 2016
The U.S. Court of Federal Claims in a recent opinion, Bishop Hill Energy LLC v. United States, ruled against a discovery request made to the U.S. Treasury
Tax Court Sheds Light on Counting Hours For the ‘Material Participation’ Exception to the Passive Activity Loss Rules
David Burton
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
Tax Court Levels Taxpayer's Weak Theories in Rent Accrual Case
David Burton
September 28, 2015
This article was originally published in the September 28, 2015 edition of Tax Notes. The Tax Court’s recent decision in Stough v. Commissioner illustrates
Project Finance Developer Fees Explained
David Burton
November 25, 2014
First published in Bloomberg BNA’s Daily Tax Report of November 25, 2014 In many renewable energy transactions, a ‘‘developer fee’’ is a critical feature—i