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...

Posted in Renewable energy Blog article

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.

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

Posted in Renewable energy 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

Posted in Renewable energy Blog article

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

Posted in Renewable energy Blog article

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

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...

Posted in Renewable energy Blog article

The U.S. Congress and Treasury Department have provided the leasing industry with five definitions of “lease term” for seven different federal income tax purposes. The resulting confusion rivals that associate

Posted in Power Renewable energy Infrastructure Solar Wind Blog article