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Inflation Reduction Act
Tax Reform and the Foreign Partner
While much has been made about international tax reform contained in the Tax Cuts and Jobs Act ("TCJA") that modifies the taxation of U.S. taxpayers with multinational holdings and operations, the new law did not leave inbound investment untouched. Notably...
The New Partnership Audit Rules, Part 1: The Basics
This is the first of several installments of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code, and related proposed and final Treasury regulations. Future installments will focus on various aspects of...
Prepaid Power Contracts
Some renewable projects, especially solar projects, use prepaid power contracts. Under a prepaid power contract, the offtaker enters into a long term contract with the supplier to buy electricity. Upon the closing, the offtaker prepays the supplier for a portion...
Recent Developments in the Private Funds Industry
1. SEC's OCIE Announces 2018 Examination Priorities 2. Tax Reform: Impact on Funds 3. New DOJ Approach to Remote Data Storage — Go Get It!
Mixed Messages on PABs: Fit for the Chopping Block or Cornerstone of Infrastructure Finance?
Only a few months ago, the public finance industry was shaken when the U.S. House of Representatives proposed to eliminate tax-exempt private activity bonds (“PABs”), despite previous assurances that tax reform would not touch tax-exempt bonds. Although the final Tax...
The New Three-Year Holding Period for Carried Interests
The Tax Cuts and Jobs Act (TCJA) modifies the holding period necessary for gains attributable to applicable partnership interests, commonly known as carried interests, to qualify as long-term capital gains, subject to federal income tax at a rate of 20%...
Department of the Treasury Releases Updated Priority Guidance Plan
On February 7, 2018, the Department of the Treasury released an update to its 2017-2018 Priority Guidance Plan. The Priority Guidance Plan describes the various guidance priorities of Treasury and the IRS for the period from July 1, 2017 through...
Bipartisan Budget Breakthrough Gives Orphans New Life
Congress last week reached a sweeping two-year budget deal, breaking a months-long legislative logjam and providing a vehicle for a laundry list of non-controversial items that had been captive to the broader standoff over immigration. In addition to establishing higher...
What to Watch: Five Key Features of the Infrastructure Package
The President has announced more details regarding the new national infrastructure initiative that he referenced during his State of the Union address. The details suggest the Administration is taking a new approach to infrastructure—coupling traditional infrastructure concepts with modern approaches...
Changing the Cost of Capital: The New Limitation on Interest Deductibility
The Tax Cuts and Jobs Act (TCJA) eliminates the earnings stripping rules, which generally applied to certain thinly-capitalized U.S. corporations paying interest to foreign affiliates. In their place, the TCJA imposes a broader limitation on the deductibility of interest that...
After Tax Bill Two-Step, Orphan Hopes Rest on Extenders
While the Tax Cuts and Jobs Act (TCJA) made the most significant changes to the tax code in a generation, with sweeping implications for all industries, the Act was conspicuously lacking in energy-specific provisions. Indeed, despite a number of proposed...
The Tax Cuts and Job Acts: Its Impact on the Energy Industry Webinar
Learn about the TCJA provisions that are most relevant to the energy industry, as well as how the reform affects business taxes, financing transactions and renewable energy credits.
Provisions Affecting the Renewable Energy and Power Industry: 100% Bonus Depreciation
Under the Tax Cuts and Jobs Act (TCJA), 100% bonus depreciation is available for qualified property acquired and placed into service after September 27, 2017 and before the end of 2022, which is a significant increase from the 50% bonus...
Rethinking Depreciation Deductions: New Opportunities for Immediate Expensing
Under the prior depreciation regime, taxpayers generally could utilize a special depreciation deduction equal to 50% of the cost of qualified property in the year the property was placed into service, with a phase down beginning after 2017. Qualified property...
Construction Contracts and Tax: A Splitting Headache?
It has become common practice in many jurisdictions for parties to split construction contracts with an international element. The split structure is intended to provide a reduced tax exposure for the contractor and a resulting pricing benefit for the employer...