There is a strong market in the transferability of IRA credits. However, be careful as there could be some unexpected state tax implications. To fuel the market for IRA credits, proposed Treasury regulations provide that the purchaser will not recognize gain on its use of the credit for federal income tax purposes (which is not … Continue Reading
Reprinted from Tax Notes State, April 15, 2024 To incentivize investment in clean or renewable energy, the Inflation Reduction Act of 2022 (IRA) created — and in some cases improved on existing — federal income tax credits availablemto investors in eligible clean or renewable energy projects. Some of these credits are popular, at least in … Continue Reading
The New York State Department of Taxation and Finance has formally proposed its 2015 corporate tax reform regulations under the State Administrative Procedure Act (SAPA). The regulations have been submitted for publication in the August 9, 2023 edition of the State Register. These regulations have a long history. There were several iterations of the draft … Continue Reading
In Matter of Sunoco Inc. (R&M) Combined Affiliates, a Division of Tax Appeals Administrative Law Judge (ALJ) determined that Sunoco’s sale of oil pursuant to buy/sell arrangements was not a “sale” for purposes of computing Sunoco’s New York State Article 9-A sales factor. The ALJ’s determination was based upon her finding that Sunoco was exchanging the … Continue Reading
The New York Budget Bill, SB.4009/A.B.3009, introduced on Sunday includes a provision allowing the NYS Department of Taxation and Finance (“Department”) to appeal determinations of the Tax Appeals Tribunal to the New York State Appellate Division under certain circumstances. Currently, the Tax Law allows only the taxpayer to appeal determinations of the Tax Appeals Tribunal. Specifically, … Continue Reading