Martha Groves Pugh Martha Groves Pugh

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  Martha (Marty) Groves Pugh advises clients on federal income tax issues with a particular emphasis on the nuclear and energy industries. Marty has helped clients seek and receive many private letter rulings and has extensive experience in drafting legislative language for tax proposals and interacting with the US Department of Treasury and the Internal Revenue Service on important industry issues. Her practice also includes tax planning for proposed transactions and advising clients on audits, appeals and litigation issues. Read Martha Groves Pugh'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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CDFI Fund Announces $7 Billion Allocation of New Markets Tax Credits


By and on Dec 9, 2016
Posted In Uncategorized

On November 17, 2016, the US Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) announced the largest single round award of New Market Tax Credit (NMTC) allocations since the program’s creation in 2001. One hundred twenty organizations, headquartered in 36 states, the District of Columbia and Puerto Rico, were awarded a total...

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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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