Philip Tingle Philip Tingle

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  Philip (Phil) Tingle represents energy companies such as utilities, independent power producers and financial institutions on a wide range of energy tax-related matters. He is the global head of the Firm's Energy Advisory Practice Group. Phil provides advice regarding all aspects of renewable-energy projects, including tax equity structures, refinancings, acquisitions and dispositions, restructurings and workouts. He has extensive experience with the production tax credit and with the application of renewable credits to new technologies. Moreover, he works with the investment tax credit for numerous kinds of solar projects. Read Philip Tingle'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...

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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...

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Six Takeaways: How Utilities and IPPs Are Responding to COVID-19


By , , , and on May 1, 2020
Posted In Natural Gas, Power Markets, Project Development and Finance, Renewables

On Thursday, April 30, McDermott was joined by Brett Kerr, vice president of external affairs at Calpine, Drew Murphy, senior vice president of strategy and corporate development at Edison International, and Andrew Campbell, director of regulatory support and planning at NiSource who shared their perspectives on how investor-owned utilities and independent power producers are managing the COVID-19 crisis....

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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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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...

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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...

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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...

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Alta Wind: Federal Circuit Reverses Trial Court and Kicks Case Back to Answer Primary Issue


By and on Aug 6, 2018
Posted In Renewables, Tax

On July 27, 2018, the US Court of Appeals for the Federal Circuit in Alta Wind v. United States, reversed and remanded what had been a resounding victory for renewable energy. The US Court of Federal Claims had ruled that the plaintiff was entitled to claim a Section 1603 cash grant on the total amount...

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SOL and the 1603 Cash Grant – File Now or Forever Hold Your Peace


By , and on May 10, 2018
Posted In Tax

Taxpayers are running out of time to file refund claims against the government. If the government reduced or denied your Section 1603 cash grant, you can file suit in the Court of Federal Claims against the government to reclaim your lost grant money. Don’t worry, you will not be alone. There are numerous taxpayers lining...

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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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