Legal Alert: IRS issues new Section 45Q CCUS ruling
Posted on Jul 9, 2021 in Legal Alerts
The IRS issued Revenue Ruling 2021-13 on July 1, 2021, which provides additional guidance regarding the section 45Q carbon capture, utilization and storage (CCUS) credit. More specifically, the ruling concludes that: A taxpayer needs to own only one component of carbon capture equipment within a single process train to be the person that is entitled to the tax credit.For section...
Legal Alert: Downsizing from a House to a Manchin: Federal and International tax negotiations continue
Posted on Jul 8, 2021 in Legal Alerts
As Congress and the White House look to make a deal on infrastructure by this summer, negotiations regarding changes in the tax law continue. Since our prior alert, while progress has been made regarding a bipartisan infrastructure deal and a minimum global tax, the details of most corporate tax proposals have yet to be decided. Of course, the most pressing question remains –...
Legal Alert: IRS extends continuity safe harbor for renewable energy projects
Posted on Jun 30, 2021 in Energy Tax, Legal Alerts
On June 29, 2021, the IRS issued Notice 2021-41, which provides a further extension of the continuity safe harbor and revises the “facts and circumstances” rules:- For PTC and ITC-eligible projects for which construction began in calendar years 2016 through 2019, the continuity safe harbor is extended to six years.- For PTC and ITC-eligible projects for which construction began in...
Legal Alert: FY 2022 Green Book goes big for green energy
Posted on Jun 1, 2021 in Energy Tax, Legal Alerts
On May 28, 2021, Treasury released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals, more commonly referred to as the Green Book. The issuance of the Green Book provides further detail on the White House’s American Jobs Plan, one of the major proposals in the development of an infrastructure bill. The Green Book’s release comes as Congress works...
Legal Alert: Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system
Posted on May 26, 2021 in Legal Alerts, Tax Accounting
Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: Allows controlled foreign corporations (CFCs) to obtain automatic consent to change depreciation methods to use the alternative depreciation system under section 168(g) (ADS) (or...