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Scission partielle et agrément préalable : une nouvelle « discrimination par ricochet »
After the failed attempt of the Marc Jacob case (Conseil d'Etat, 31 May 2016, No. 393881, Jacob), the decision of the French Administrative Supreme Court dated 16 September 2019
10 Oct 2019
Applying Acquisition Price Method To Post-TCJA Platform Contribution Transactions
Prior to the Tax Cuts and Jobs Act of 2017 ("TCJA"), the appeal of cost sharing was driven largely by the deferral of U.S. taxation on foreign earnings.
United States
13 Aug 2019
Capital Markets Tax Quarterly - Volume 2, Issue 2
Q2 2019 started out with a great deal of hope in the world of capital markets taxation.
United States
6 Aug 2019
IRS Releases 2019 Section 45 Production Tax Credit Amounts
On June 6, 2019, the US Internal Revenue Service (IRS) published a notice providing the inflation-adjustment factors and reference prices for the calculation of renewable electricity PTCs under IRC section 45 for 2019.
United States
25 Jul 2019
IRS Issues Proposed Regulations Regarding Withholding Under Section 1446(f)
On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the "IRS") released proposed regulations regarding Section 1446(f)
United States
15 Jul 2019
How To Structure A Tax-Efficient IPO: Benefits Of The Up-C Structure
A partnership (or LLC) can go public in a highly tax-efficient manner by using an "Up-C" structure. An Up-C structure is composed of two entities: (1) a parent company,
United States
30 May 2019
Legal Update: Section 956's "Deemed Dividend" Rules: An Update For Lenders On Proposed Changes
Section 956 of the US Internal Revenue Code ("Section 956") has historically loomed large in the context of finance transactions because it limited the ability of US borrowers to use overseas assets
United States
23 Apr 2019
Cadillac Tax Repeal On The Horizon?
The Affordable Care Act contains a provision–the so-called "Cadillac tax"–providing for a 40% exciClassic Cadillacse tax on high cost employer-sponsored health coverage.
United States
21 Mar 2019
Infocast's Wind Finance & Investment Summit Soundbites
Below are soundbites from panelists who spoke at Infocast's Wind Finance & Investment Summit on February 6 and 7 in Carlsbad, CA.
United States
8 Mar 2019
BEATen Up (Again): The IRS Issues Proposed Regulations Under The Base Erosion Anti-Abuse Tax
On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.
United States
25 Jan 2019
IRS Releases Proposed Anti-Hybrid Regulations
The US Tax Cuts and Jobs Act of 2017 added new sections 245A(e) and 267A to the Code. Section 245A(e) denies the section 245A dividends-received deduction for "hybrid" dividends.
United States
8 Jan 2019
Solar Power International 2018: Soundbites
Below are soundbites from panel discussions at Solar Power International on September 25 and 26 in Anaheim, California.
United States
4 Jan 2019
Treasury Releases Proposed Regulations On Foreign Tax Credits Under New International Tax Rules
On November 28, 2018, the US Department of Treasury and Internal Revenue Service released proposed regulations on the determination of foreign tax credits
United States
27 Dec 2018
Hawaii: Solar System Is Not Placed In Service Until All State Law Requirements Have Been Satisfied
In September, the State of Hawaii Department of Taxation issued a letter ruling (Hawaii Letter Ruling No. 2018-01) that clarified the "placed in service" requirement in the application of the Renewable Energy Technologies Income Tax Credit ("RETITC") in Hawaii.
United States
14 Dec 2018
Tax Equity Webinar Q&A
Below are answers to questions we received during our tax equity webinar of October 23. These questions were submitted online during the webinar.
United States
13 Dec 2018
The In-State Corporation's Solution To "Expedia" Apportionment
Mayer Brown lawyers discuss New York's "other reasonable method" for apportioning receipts and the opportunity it may provide for certain in-state taxpayers to reduce their New York apportionment percentages...
United States
12 Dec 2018
NREL's 2018 PV Project Finance Report
David Feldman and Paul Schwabe of the National Renewable Energy Laboratory (NREL) have published their annual solar PV financing report: Terms, Trends, and Insights on PV Project Finance...
United States
5 Dec 2018
Power Finance & Risk – Tax Equity Roundtable 2018 Report
We were pleased to participate in Power Finance & Risk's (PFR) Tax Equity Roundtable. We were joined in the roundtable discussion by Rich Dovere of C2 Energy Capital, Marshal Salant of Citi,
United States
14 Nov 2018
Environmental, Social And Governance Investing Event: Solar ITC & Qualified Opportunity Zone Presentation
I was a panelist at an event held at Mayer Brown's New York office addressing Environmental, Social and Governance ("ESG") ...
United States
17 Oct 2018
IRS Further Extends Phase-In Of Section 871(m) Regulations By 'Another' 2 Years
On September 20, 2018, the US Internal Revenue Service ("IRS") released Notice 2018-72 (the "Notice") ...
United States
26 Sep 2018
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