Bradford E. LaBonte Bradford E. LaBonte

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  Bradford E. LaBonte focuses his practice on US and international tax matters. He advises multinational corporations and investment funds on matters related to cross-border mergers and acquisitions, cash repatriation, controlled foreign corporation (CFC) and passive foreign investment company (PFIC) regimes, financial instrument classification, US trade or business determinations, US income tax treaty qualification and planning, and US withholding tax issues. Read Bradford LaBonte's full bio.

The Senate’s New Base Erosion Tax: Highlights for Renewable Energy


By , , , and on Dec 8, 2017
Posted In Renewables, Tax, U.S. Congress

On December 2, 2017, the Senate approved its version of the Tax Cuts and Jobs Act. The Senate Bill includes the base erosion and anti-abuse tax, a new tax intended to apply to companies that significantly reduce their US tax liability by making cross-border payments to affiliates. Given its potential to disrupt the financing of...

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IRS Issues Guidance on Tax Treatment of Energy Savings Performance Contracts


By , , and on Feb 2, 2017
Posted In Uncategorized

On January 19, 2017, the Internal Revenue Service (IRS) issued Rev. Proc. 2017-19, 2016-6 I.R.B. (the Rev. Proc.), providing a safe harbor under which it will not challenge the tax treatment of an Energy Savings Performance Contract Energy Savings Agreement (ESPC ESA) as a service contract under Section 7701(e)(3). While the application of the guidance...

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IRS Issues Additional Guidance on Beginning of Construction Rules for Renewable Projects


By , , , and on Dec 21, 2016
Posted In Environmental, Power Markets, Renewables, Tax

On December 15, 2016, the Internal Revenue Service released Notice 2017-04, which provides welcome guidance on how to meet the “beginning of construction” requirements for wind and other qualified facilities. There has been much uncertainty about when construction of these types of facilities begins for renewable energy tax credit purposes. The Notice (1) extends the...

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Final Regulations Define ‘Real Property’ for REITs: Considerations for Renewable Energy and Transmission Assets


By , , , and on Sep 29, 2016
Posted In Renewables, Tax, Uncategorized

On August 31, 2016, the Internal Revenue Service (IRS) and US Department of the Treasury issued final regulations (Final Regulations) under section 856 of the Internal Revenue Code to clarify the definition of “real property” for purposes of sections 856 through 859 relating to real estate investment trusts (REITs). The Final Regulations largely follow proposed...

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