IRS Releases New Guidance On Beginning of Renewable Energy Project Construction

IRS Releases New Guidance On Beginning of Renewable Energy Project Construction

The IRS recently released Notice 2014-46 (the Notice) which provides welcome guidance to tax equity investors and developers on the construction of wind, geothermal, biomass, landfill gas and certain hydropower and marine hydrokinetic energy projects for purposes of qualifying for the section 45 renewable electricity production tax credit (PTC), or the section 48 investment tax credit (ITC) in lieu of the PTC.

Internal Revenue Service Agrees to Settle Transfer Pricing Case Filed in the United States Tax Court Against Caterpillar Inc.

Internal Revenue Service Agrees to Settle Transfer Pricing Case Filed in the United States Tax Court Against Caterpillar Inc.

In a case that had been docketed in the United States Tax Court, Caterpillar Inc. v. Commissioner, Docket No. 10790-13 (2013), the petitioner-corporation and respondent, Internal Revenue Service, entered into and filed a stipulated settlement on July 31, 2014 with the Court.