Martha Groves Pugh Martha Groves Pugh

Subscribe to Martha Groves Pugh's Posts
  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 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...

Continue Reading



Energy Tax Extenders in FAA Bill Unlikely


By , , , and on Jun 30, 2016
Posted In Environmental, Project Development and Finance, Renewables, Tax, U.S. Congress

As discussed in our post on April 7, US Congress extended the Production Tax Credit (PTC) under Internal Revenue Code (IRC) Section 45 and the Investment Tax Credit (ITC) under IRC Section 48 in December 2015, but failed to include extensions for certain types of renewable energy property, including fuel cell power plants, stationary microturbine power...

Continue Reading



IRS Revises Recent Begin Construction Guidance


By , , , and on May 20, 2016
Posted In Renewables, Tax

On May 18, 2016, the Internal Revenue Service (IRS) revised Notice 2016-31 (Notice), its recent guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass, geothermal, landfill gas, trash, hydropower, and marine and hydrokinetic facilities). For a discussion of the Notice, click here. The revisions clarify that the Continuity...

Continue Reading



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


By , , , and on May 11, 2016
Posted In Renewables, Tax

The Internal Revenue Service recently issued Notice 2016-31, which provides much-needed guidance for wind and other qualified facilities on meeting the beginning of construction requirements in light of the 2015 statutory extension and modification of the production tax credit and the investment tax credit. The Notice also revises and adds to the list of excusable disruptions...

Continue Reading



Short-Term Reauthorization of FAA Programs Potentially Paves the Way For Omitted Energy Credit Extenders


By , , , and on Apr 7, 2016
Posted In Project Development and Finance, Renewables, Tax, U.S. Congress

As discussed in our post on March 16, the Congressional extension of the Production Tax Credit (PTC) under Internal Revenue Code (IRC) Section 45 and the Investment Tax Credit (ITC) under IRC Section 48 in December 2015 failed to include extensions for certain types of renewable energy property, including fuel cell power plants, stationary microturbine...

Continue Reading



President Obama Signs Consolidated Appropriations Act


By , , , and on Mar 16, 2016
Posted In Project Development and Finance, Renewables, Tax, U.S. Congress

Renewable Energy Industry Seeks Additional Energy Credit Clarifications On December 18, 2015, President Barack Obama signed into law the Consolidated Appropriations Act, 2016 (H.R. 2029) (the Act). The Act includes multi-year extensions of the Production Tax Credit (the PTC) under Internal Revenue Code (IRC) Section 45 and the Investment Tax Credit (the ITC) under IRC...

Continue Reading



Key Energy-Related Tax Provisions in the 2017 Budget Proposal


By , , , and on Feb 23, 2016
Posted In Environmental, Natural Gas, Renewables, Tax, U.S. Congress

President Obama’s recently released budget proposal for the 2017 fiscal year repeats many of his past energy-related tax proposals, including a permanent extension of the renewable energy production tax credit and a provision making it refundable. Making the production tax credit permanent and refundable signals the administration’s continued strong support for renewable energy. This On...

Continue Reading



What Must Be Done for Wind and Solar Projects to Have “Begun Construction” under the New PTC and ITC?


By , , , and on Feb 5, 2016
Posted In Project Development and Finance, Renewables, Tax

With the recent extension of the federal income tax credits available for renewable energy projects, practitioners and industry participants have raised questions as to how the “begun construction” rules will apply under these new regimes.  The new regimes refer to the dates on which construction on projects began for purposes of determining qualification for the...

Continue Reading



Extension of Renewable Energy Tax Incentives


By , , , , and on Jan 14, 2016
Posted In Environmental, Renewables, U.S. Congress

On December 18, 2015, President Barack Obama signed into law the Consolidated Appropriations Act, 2016 (H.R. 2029) (the Act), which included welcomed extensions to a number of energy tax incentives. The legislation includes multi-year extensions of the Section 45 Production Tax Credit (the PTC) and the Section 48 Investment Tax Credit (the ITC) for wind and...

Continue Reading



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


By , , and on Mar 23, 2015
Posted In Renewables, Tax

The Internal Revenue Service issued Notice 2015-25 on March 11, 2015, to provide further guidance on meeting the beginning of construction requirements for wind and other qualified facilities. The Notice extends the date by which a facility can meet the beginning of construction deadline to correspond with the extension of Code Section 45 passed by...

Continue Reading



STAY CONNECTED

TOPICS

ARCHIVES