Daniel Nelson

May 3, 2024 | morganlewis.com | Richard C. LaFalce |Sarah-Jane Morin |Daniel Nelson |Kendall J. Keshtkar

On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892 of the Internal Revenue Code of 1986, as amended (the Code), providing guidance related to “domestically controlled” qualified investment entities and exemptions for foreign government investors, respectively.

Jan 31, 2024 | morganlewis.com | Richard M Filosa |Ashley Keenan |Kristin M. Hasselgren |Daniel Nelson |Meghan McCarthy |Harry T. Robins | +1 more

BOSTON, JANUARY 31, 2024: Morgan Lewis advised Ares Management Corp. on its sale of Heelstone Renewable Energy, a US utility-scale renewable energy platform, to Qualitas Energy. Headquartered in Chapel Hill, North Carolina, Heelstone holds a portfolio of 20 GW comprising solar photovoltaic (PV) and storage assets, including operational, under-construction, ready-to-build, and in-development projects.

Jan 31, 2024 | morganlewis.com | Richard M Filosa |Ashley Keenan |Kristin M. Hasselgren |Daniel Nelson |Meghan McCarthy |Harry T. Robins | +1 more

BOSTON, JANUARY 31, 2024: Morgan Lewis advised Ares Management Corp. on its sale of Heelstone Renewable Energy, a US utility-scale renewable energy platform, to Qualitas Energy. Headquartered in Chapel Hill, North Carolina, Heelstone holds a portfolio of 20 GW comprising solar photovoltaic (PV) and storage assets, including operational, under-construction, ready-to-build, and in-development projects.

May 25, 2023 | lexology.com | Sarah-Jane Morin |Richard Zarin |Daniel Carmody |Daniel Nelson |Scott Lee |Kendall J. Keshtkar

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.

May 25, 2023 | morganlewis.com | Sarah-Jane Morin |Richard Zarin |Daniel Carmody |Daniel Nelson

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.