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Proposed regulations provide FATCA compliance guidance for foreign financial institutions, other foreign entities and U.S. withholding agents

USA - March 27 2012 The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471– 1474 of the Internal Revenue Code.

Treasury clarifies 5 percent safe harbor ownership guidelines for Section 1603 grants for renewable energy projects

USA - December 13 2011 The Treasury Department has issued guidance in the form of two new “Frequently Asked Questions” addressing when transferees or purchasers of renewable energy property will qualify for the 5 percent safe harbor for beginning construction under the grant in lieu of investment credit program.

Madeline M. Chiampou, Martha Groves Pugh, Philip Tingle

Comparison of key energy-related tax provisions in the President’s 2015 Budget Proposal and the Camp and Baucus Proposals

USA - April 14 2014 On March 4, 2014, President Obama released his budget proposal for the 2015 fiscal year (Budget Proposal), which contains energy-related tax…

Martha Groves Pugh, Philip Tingle, Madeline Chiampou Tully

IRS provides safe harbor for allocating success-based fees

USA - April 29 2011 The release by the Internal Revenue Service (IRS) on April 8, 2011 of Revenue Procedure 2011-29 provides a welcome new safe harbor for taxpayers with respect to the deductibility of "success-based fees" paid in connection with business acquisitions and reorganizations.

IRS issues additional guidance on when construction begins for purposes of production tax credit, investment tax credit

USA - September 25 2013 The Internal Revenue Service (IRS) has issued additional guidance relating to when construction begins with respect to wind and other qualified…

Martha Groves Pugh, Philip Tingle, Madeline Chiampou Tully