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Energy

Subsidy payments by state energy organization not taxable to homeowner beneficiaries

Subsidy payments by state energy organization not taxable to homeowner beneficiaries

PLR 201607004 In a private letter ruling, IRS has concluded that amounts paid by a state organization to contractors who install solar energy systems in the homes of homeowners, as part of a program to increase energy efficiency, are not taxable to the homeowners and that the organization need not file information returns with IRS […]

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IRS provides procedures for claims related to retroactively extended fuel credits

IRS provides procedures for claims related to retroactively extended fuel credits

Notice 2016-5, 2016-6 IRB To take into effect the retroactive extension of certain fuel tax credits under the Protecting Americans from Tax Hikes (PATH) Act, IRS has issued a Notice that provides rules that taxpayers must follow to make a one-time claim for a refund of, or credit for, certain fuels sold or used during […]

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Seismic studies bought along with proven oil and gas properties aren’t amortizable

Seismic studies bought along with proven oil and gas properties aren’t amortizable

Chief Counsel Advice 201552024 In Chief Counsel Advice (CCA), IRS concluded that the costs of seismic data acquired as part of an asset acquisition weren’t geological and geophysical (G&G) exploration costs eligible for amortization under Code Sec. 167(h). The seller used the seismic data to locate and identify productive oil and gas properties, which it […]

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Energy Tax Provisions in the “Protecting Americans from Tax Hikes” Act

Energy Tax Provisions in the “Protecting Americans from Tax Hikes” Act

The “Protecting Americans from Tax Hikes (PATH) Act of 2015”. Summary of the PATH Act. Late on December 15, a bipartisan, bicameral agreement was reached on tax extenders—i.e., the 50 or so temporary tax provisions that are routinely extended by Congress on a one- or two-year basis—and numerous other tax provisions in the “Protecting Americans […]

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IRS request comments on property qualifying for the Sec. 48 energy credit

IRS request comments on property qualifying for the Sec. 48 energy credit

Notice 2015-70, 2015-42 IRB In a Notice, IRS has requested comments on issues that should be addressed in proposed regs on the definition of certain types of property under Code Sec. 48.Comments must be received by Feb. 16, 2016. Background.For purposes of computing the investment credit under Code Sec. 46, Code Sec. 48(a)(1) provides, in part, […]

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30% credit OK’d for solar energy panels in offsite community-shared project

30% credit OK’d for solar energy panels in offsite community-shared project

PLR 201536017 In a private letter ruling (PLR), IRS says that an individual can claim a 30% residential energy efficient property credit under Code Sec. 25D for the cost of solar panels (and a partial ownership interest in related equipment) installed in an offsite community-shared solar project. The Clean Energy States Alliance, an industry group, […]

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LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

A recently released memorandum to all employees at IRS’s Large Business and International (LB&I) Division provides guidance to IRS examiners on how to determine when a major component pertaining to steam or electric generation property has been replaced under Reg. § 1.263(a)-3(k). The memo generally provides that a major component is considered to be replaced, […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney