Here’s is a link to my interview on the topic of tax equity with the Stratton Report: Tax Equity Interview
Depreciation
Structuring, Modeling and HLBV Accounting for Tax Equity: Presentation and Questions and Answers
We are pleased to make available the materials from our June 29 tax equity seminar.
Here’s is the link to a PDF of the slides: Seminar Slides PDF.
The webinar audience submitted questions that we did not have time to answer. The questions were:
1. Why do balance sheet players have an advantage in…
IRS Updates Safe Harbor for Transfers of Interties to Utilities
On June 10, the IRS issued Notice 2016-36, available at https://www.irs.gov/pub/irs-drop/n-16-36.pdf (the “Notice”), which updates and expands the existing safe harbor[1] pursuant to which the transfer of an intertie (or reimbursement for the cost thereof) to a regulated public utility will be treated as a contribution to the capital of a corporation, and not…
Tax Equity Seminar: Structuring, Modeling & HLBV Accounting on June 29
Topics addressed in the program will include:
- The IRS’s updated “start of construction” guidance for tax credit qualification
- Trends in the tax equity market
…
All Drywall Systems Aren’t Created Equal Under MACRS
First published in Bloomberg BNA’s Daily Tax Report on May 15, 2014
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 Service’s ruling in the PLR with consistent federal appeals court decisions that preceded it—but…
IRS Blesses TRAC Lease Securitization
This article was first published by Bloomberg BNA Daily Tax Report on February 24, 2014
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 rental adjustment clause (TRAC) provided for in Section 7701(h).…