Archive - December 2013
Rev. Proc. 2014-12: New Safe Harbor for Tax Equity Deals
Yesterday Treasury released the much anticipated post- Historic Boardwalk safe-harbor applicable to certain tax equity deals. This is the second safe-harbor that the IRS has released in the domain of tax equity transactions. The first one was released in 2007 (Rev. Proc. 2007-65 applicable to wind energy projects). For readers that do not specialize in this area, tax equity transactions are prevalent in the energy sector and other sectors that offer tax credits or other incentives to stimulate particular activities (for example, historic rehabilitation in the case of Historic Boardwalk). ...
December 31, 2013 read more
Dividend Equivalent Proposed Regulations Clip the Wings of Single Stock Futures
On December 5th Treasury released final and proposed regulations under Sec. 871(m). This section deals with dividend equivalent payments and it was designed to shut down tax avoidance run around U.S. dividend withholding rules. For previous coverage, see here. The regulations withdraw a set of previous proposed regulations (from Jan 2012) and replace them with a regime which appears to be more detrimental to the hedge fund industry. Many of the provisions of the proposed regulations do not kick in until several years down the road (for e.g. rules on Specified ELIs apply after...
December 10, 2013 read more