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

Here are the slides from a presentation that I gave at the 2015 Solar Energy Industry Association (SEIA) Finance and Tax Seminar about the foundations of sale-leasebacks.

On Oct. 31, the U.S. Internal Revenue Service (IRS) released Private Letter Ruling (PLR) 201444025, which was addressed to a manufacturer of solar...

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

Many wind developers regularly require additional capital infusion and keep their eyes peeled for opportunities to raise it. Three recent trends in public equity transactions for developers are yieldcos, listin

Posted in Wind 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