Nicholas Mowbray

Jun 18, 2024 | jdsupra.com | Nicholas Mowbray |Jeffrey Paravano

Key Takeaways The proposed regulations set forth proposed guidance regarding measurement of greenhouse gas (GHG) emissions rates for purposes of the 45Y and 48E credits. The replacement of Section 45 and 48 credits with 45Y and 48E credits will not significantly change the qualification standards for wind, solar and geothermal qualified facilities because the proposed regulations identify them as zero-rate GHG emissions facilities.

Jun 18, 2024 | lexology.com | Nicholas Mowbray |Jeffrey Paravano

Key TakeawaysThe proposed regulations set forth proposed guidance regarding measurement of greenhouse gas (GHG) emissions rates for purposes of the 45Y and 48E credits. The replacement of Section 45 and 48 credits with 45Y and 48E credits will not significantly change the qualification standards for wind, solar and geothermal qualified facilities because the proposed regulations identify them as zero-rate GHG emissions facilities.

Jun 12, 2024 | jdsupra.com | John Carney |Jessica Mingrino |Nicholas Mowbray

Time Running Out for Disclosure OptionsKey Takeaways: The IRS is devoting greater resources to investigating and auditing wealthy Americans who have taken advantage of Puerto Rico’s lucrative tax benefits. The IRS continues to face external pressure from Congress to curb abuses of Puerto Rico’s tax benefits – results are to be expected in the form of increased IRS examinations and, in certain circumstances, criminal charges being brought for violations.

Jun 12, 2024 | lexology.com | CARLOS ORTIZ |Kayley B. Sullivan |Nicholas Mowbray |Jessica Mingrino |John Carney

Time Running Out for Disclosure OptionsKey Takeaways:The IRS is devoting greater resources to investigating and auditing wealthy Americans who have taken advantage of Puerto Rico’s lucrative tax benefits. The IRS continues to face external pressure from Congress to curb abuses of Puerto Rico’s tax benefits – results are to be expected in the form of increased IRS examinations and, in certain circumstances, criminal charges being brought for violations.

May 1, 2024 | jdsupra.com | Nicholas Mowbray |Jeffrey Paravano

The IRS and the Treasury Department on April 25 published final regulations relating to the one-time transfer election under § 6418. The final regulations under § 6418 were issued approximately seven weeks after the final regulations under § 6417, relating to direct pay. Both sets of final regulations provide important guidance for taxpayers interested in monetizing certain renewable energy credits.