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  Heather Cooper works on federal income tax matters, with a focus on energy tax issues. She represents clients in restructurings, mergers and acquisitions, and other transactional energy related matters. Heather's national practice includes advising on all aspects of renewable energy transactions such as solar and wind projects. She provides advice on tax equity structures, refinancings, acquisitions and dispositions, restructurings and workouts. Read Heather Cooper's full bio.

Senate Passes Tax Extenders Deal That Includes Extension of Renewable Energy Incentives


By , and on Dec 19, 2019
Posted In Uncategorized

The US Senate today passed a package of tax extenders as part of the year-end appropriations act that the US House of Representatives passed on December 17, 2019. President Trump is expected to sign the legislation before the end of the day tomorrow to avoid a government shutdown. The package includes a one-year extension of...

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Court Rules That Wind Farm Did Not Provide Proof of Development Fee to Receive 1603 Cash Grant


By , , and on Jul 2, 2019
Posted In Court Procedure Matters, Tax Refunds, Trial Courts, Uncategorized

On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party transactions may appropriately determine the cost basis with respect to a wind energy project under the Internal Revenue Code (IRC). Central...

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Analysis of Energy and Tax Proposals in the 2018 Budget Proposal


By , , and on May 26, 2017
Posted In Tax Refunds, Uncategorized

President Trump released his budget proposal for the 2018 FY on May 23, 2017, expanding on the budget blueprint he released in March. The budget proposal and blueprint reiterate the President’s tax reform proposals to lower the business tax rate and to eliminate special interest tax breaks. They also provide for significant changes in energy...

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Court Awards $206 Million in Section 1603 Grant Wind Project Case


By and on Nov 3, 2016
Posted In Court Procedure Matters, Tax Refunds, Trial Courts, Uncategorized

The US Court of Federal Claims awarded damages of more than $206 million to the plaintiffs in a case involving the cash grant program pursuant to Section 1603 of the American Recovery and Reinvestment Act of 2009 (the Section 1603 Grant).  In its opinion, published on October 31, 2016, the court held that the US...

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Investment Tax Credit Lessee Income Inclusion Guidance Issued


By , , , , and on Jul 26, 2016
Posted In IRS Guidance, Uncategorized

New Internal Revenue Service temporary regulations provide guidance on the income inclusion rules that apply when a lessor elects to treat a lessee as having acquired investment credit property under Treas. Reg. § 1.48-4. As expected, the new temporary regulations also provide that a partner of a lessee partnership cannot increase its basis in its...

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IRS Revises Recent Begin Construction Guidance


By , , , , and on May 20, 2016
Posted In IRS Guidance, Uncategorized

On May 18, 2016, the Internal Revenue Service (IRS) revised Notice 2016-31 (Notice), its recent guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass, geothermal, landfill gas, trash, hydropower, and marine and hydrokinetic facilities). For a discussion of the Notice, click here. The revisions clarify that the Continuity...

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IRS Issues Guidance on the Beginning of Construction Rules for Renewable Projects


By , , , , and on May 11, 2016
Posted In IRS Guidance, Uncategorized

The Internal Revenue Service recently issued Notice 2016-31, which provides much-needed guidance for wind and other qualified facilities on meeting the beginning of construction requirements in light of the 2015 statutory extension and modification of the production tax credit and the investment tax credit. The Notice also revises and adds to the list of excusable...

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