Heather Cooper Heather Cooper

Subscribe to Heather Cooper's Posts
  Heather Cooper works on federal income tax matters, with a focus on energy tax issues. She represents clients in restructurings, mergers and acquisitions, and other transactional energy related matters. Heather's national practice includes advising on all aspects of renewable energy transactions such as solar and wind projects. She provides advice on tax equity structures, refinancings, acquisitions and dispositions, restructurings and workouts. Read Heather Cooper's full bio.

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...

Continue Reading



IRS Extends Deadline for ITC and PTC Projects


By and on May 28, 2020
Posted In Renewables, Tax

The IRS yesterday released anticipated guidance extending the placed-in-service deadline for the Investment Tax Credit (ITC) and Production Tax Credit (PTC). Under Notice 2020-41, the “Continuity Safe Harbor” was extended to five years for any project that otherwise began construction in 2016 or 2017. As background, the applicable credit rate for the ITC and PTC turns...

Continue Reading



Five Takeaways: Navigating President Trump’s Executive Order on US Bulk Power System Electric Equipment


By , , , and on May 22, 2020
Posted In Power Markets, Project Development and Finance, Renewables, Tax

President Trump’s May 1, 2020 Executive Order prohibiting certain transactions involving bulk-power system electric equipment developed, manufactured or supplied by a foreign adversary could have far-reaching implications for both the renewable and conventional power industries. It has also raised a high level of uncertainty and risk while the industry awaits the actual implementation of the...

Continue Reading



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...

Continue Reading



Senate Passes Tax Extenders Deal That Includes Extension of Renewable Energy Incentives


By , , and on Dec 19, 2019
Posted In Project Development and Finance, Renewables, Tax, U.S. Congress

The US Senate today passed a package of tax extenders as part of the year-end appropriations act that the US House of Representatives passed on December 17, 2019. President Trump is expected to sign the legislation before the end of the day tomorrow to avoid a government shutdown. The package includes a one-year extension of...

Continue Reading



House Passes PTC, NMTC Extension Bill


By and on Dec 18, 2019
Posted In Project Development and Finance, Renewables, Tax

On December 17, 2019, the US House of Representatives passed a year-end fiscal year 2020 spending bill for the federal government that includes a one-year extension of the production tax credit under Section 45 (PTC) for wind and other technologies. The bill would extend the wind PTC for facilities the construction of which begins during...

Continue Reading



Court Rules That Wind Farm Did Not Provide Proof of Development Fee to Receive 1603 Cash Grant


By , , and on Jun 28, 2019
Posted In Environmental, Project Development and Finance, Tax

On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party transactions may appropriately determine the cost basis with respect to a wind energy project under the Internal Revenue Code (IRC). Central...

Continue Reading



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...

Continue Reading



Initial Republican Tax Reform Proposal Includes Tax Cuts and Changes to Energy Credits


By , , , and on Nov 3, 2017
Posted In Featured, Power Markets, Project Development and Finance, Renewables, Tax, U.S. Congress

Changes to the energy credits proposed in the Tax Cuts and Jobs Act could impact the eligibility of renewable energy projects that had been relying on the guidance previously issued by the Internal Revenue Service. Continue Reading

Continue Reading



Analysis of Energy and Tax Proposals in the 2018 Budget Proposal


By , , and on May 25, 2017
Posted In Project Development and Finance, Renewables, Tax, U.S. Congress

President Trump released his budget proposal for the 2018 FY on May 23, 2017, expanding on the budget blueprint he released in March. The budget proposal and blueprint reiterate the President’s tax reform proposals to lower the business tax rate and to eliminate special interest tax breaks. They also provide for significant changes in energy...

Continue Reading



STAY CONNECTED

TOPICS

ARCHIVES