IRS Releases Favorable Guidance For Individual Investors To Claim Section 25D Tax Credit

The IRS recently issued a Private Letter Ruling (PLR) clarifying that an individual investor in a net-meted community solar project may claim the federal residential Investment Tax Credit (ITC) under Section 25D of the Internal Revenue Code. (A copy of the PLR is available here.) The PLR is also significant because it appears to eliminate a number of contractual requirements that the utility and taxpayer needed to agree to regarding the tracking and ownership […]

By |September 21st, 2015|

The Taxation Of Various Canadian Acquisition Vehicles

Often the determination of what type of entity to acquire a business with is driven by the most tax efficient structure. Here we will review some of the most commonly used entities and how amounts that are extracted from a business by those entities are taxed in Canada. The most commonly used entity is the corporation. In Canada, a corporation is considered a separate legal entity from its shareholders and is taxed accordingly. Where […]

By |September 18th, 2015|

NJ Tax Court Finds Royalty Company Must File And Pay Even Though Related Entity Paid Tax On Same Income

In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the taxpayer, even though the related entity from which the taxpayer received royalty payments had filed a CBT return and included the same payments in […]

By |September 16th, 2015|