Martha Groves Pugh
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Martha (Marty) Groves Pugh advises clients on federal income tax issues with a particular emphasis on the nuclear and energy industries. Marty has helped clients seek and receive many private letter rulings and has extensive experience in drafting legislative language for tax proposals and interacting with the US Department of Treasury and the Internal Revenue Service on important industry issues. Her practice also includes tax planning for proposed transactions and advising clients on audits, appeals and litigation issues. Read Martha Groves Pugh's full bio.
Final Section 468A Regulations Issued at Last
By Martha Groves Pugh, Justin Jesse and Brian Moore 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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IRS Releases Initial Section 45Q Carbon Sequestration Credit Guidance
By Brian Moore, Heather Cooper, Justin Jesse, Martha Groves Pugh and Philip Tingle 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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Senate Passes Tax Extenders Deal That Includes Extension of Renewable Energy Incentives
By Martha Groves Pugh, Justin Jesse, Heather Cooper and Philip Tingle 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...
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Court Rules That Wind Farm Did Not Provide Proof of Development Fee to Receive 1603 Cash Grant
By Martha Groves Pugh, Kevin Spencer, Heather Cooper and Philip Tingle 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...
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FERC Announces Tax Reform Actions and Eliminates Income Tax Allowance for Master Limited Partnerships
By McDermott Will & Emery and Martha Groves Pugh on Mar 23, 2018
Posted In FERC, Natural Gas, Power Markets, Project Development and Finance, Tax
FERC announced actions in response to the 2017 tax reform legislation and a revised income tax policy, which eliminates the income tax allowance for Master Limited Partnerships. Regulated entities should ensure that they comply with FERC’s orders regarding the treatment of income taxes and consider whether to file comments on the proposed rulemaking and notice...
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The Senate’s New Base Erosion Tax: Highlights for Renewable Energy
By McDermott Will & Emery, Bradford E. LaBonte, Heather Cooper, Martha Groves Pugh and Philip Tingle 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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Initial Republican Tax Reform Proposal Includes Tax Cuts and Changes to Energy Credits
By McDermott Will & Emery, Heather Cooper, Kevin Spencer, Martha Groves Pugh and Philip Tingle 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
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Analysis of Energy and Tax Proposals in the 2018 Budget Proposal
By McDermott Will & Emery, Heather Cooper, Martha Groves Pugh and Philip Tingle 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...
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IRS Issues Additional Guidance on Beginning of Construction Rules for Renewable Projects
By Martha Groves Pugh, Heather Cooper, Bradford E. LaBonte, McDermott Will & Emery and Philip Tingle 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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CDFI Fund Announces $7 Billion Allocation of New Markets Tax Credits
By K. Christy Vouri-Misso and Martha Groves Pugh on Nov 29, 2016
Posted In Project Development and Finance, Renewables, Tax
On November 17, 2016, the US Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) announced the largest single round award of New Market Tax Credit (NMTC) allocations since the program’s creation in 2001. One hundred and twenty organizations, headquartered in 36 states, the District of Columbia and Puerto Rico, were awarded a...
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