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Brian Moore focuses his practice on US and international tax matters. Read Brian Moore's full bio.

Final Section 468A Regulations Issued at Last


By , and on Sep 11, 2020
Posted In Environmental, Tax

On September 4, 2020, the Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) published in the Federal Register final regulations under section 468A of the Internal Revenue Code (the Code) that address three issues raised by the nuclear electric industry concerning qualified nuclear decommissioning funds (“qualified funds”). These final regulations conclude a many...

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Six Takeaways: Utilization and Structuring for Section 45Q Carbon Capture Credits


By , , and on Jun 12, 2020
Posted In Environmental, Natural Gas, Project Development and Finance, Renewables, Tax

On Thursday, June 11, McDermott partners Phil Tingle, Heather Cooper and Jacob Hollinger were joined by Ken Ditzel, managing director at FTI Consulting, to discuss their insights into the proposed Section 45Q carbon capture and sequestration credit regulations. The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration...

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IRS Releases Initial Section 45Q Carbon Sequestration Credit Guidance


By , , , and on Feb 21, 2020
Posted In Environmental, Natural Gas, Project Development and Finance, Renewables, Tax

Treasury and the IRS released initial guidance on the amended Section 45Q carbon oxide sequestration credit on February 19, 2020. Notice 2020-12 and Revenue Procedure 2020-12 provide guidance relating to the beginning of construction and tax equity partnership allocations. This is the first Section 45Q guidance since Treasury issued a request for comments in Notice...

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