Finding Tool for Public Comment Letters Filed Regarding the Direct Pay and Transferability Provisions (§ 6417) and Elective Credit Transfer Provisions (§ 6418) of the Inflation Reduction Act of 2022
The IRS published Notice 2022-50 on October 10, 2022, calling for public comments on the elective payment and credit transfer provisions of the Inflation Reduction Act of 2022 (Public Law 117-169, 136 Stat. 2003 (August 16, 2022)) to be filed by November 4, 2022. Over 190 letters were filed in response. These letters contained specific comments and questions which will be available for use by the Treasury and IRS in anticipation of guidance on implementing § 6417 and § 6418.
Baker Botts has prepared this finding tool below that organizes the letters alphabetically by commenter name and lists the topics addressed in each letter. We reviewed each letter that was filed to develop our summary of the topics covered by that letter. Recognizing that browsing through the comments on Regulations.gov to find the letters of interest is very cumbersome, this is our contribution to facilitating development of the needed guidance on these new provisions. With this table, although you cannot do a word search through the text of all the letters, you can search for the letters we have indicated cover a topic of interest (for example, use Control + f to find all letters commenting on “recapture”). We hope you will find this tool useful.
|
Commenter Name |
Signed By |
Topic |
Comment Document |
|
26 Organizations |
Center for American Progress |
Identification; monitoring; general guidance |
|
|
ACP, ACORE, AEE, SEIA |
JC Sandberg |
General comments |
|
|
Advanced Energy Economy |
Nat Kreamer |
Eligible entities; tax-exempt entities; documentation; recapture; third-party ownership; partnership eligibility; S corporation eligibility |
|
|
Afloat, Inc. |
Afloat, Inc. |
Documentation |
|
| Alliant Energy | Robert Durian, Jennifer Janecek |
Normalization for public utilities | Alliant Energy Comments |
|
Air Company |
Natalia Sharova |
Direct Pay timing; Procedures following 5-year Direct Pay period |
|
|
American Chemistry Council |
Kimberly Wise White |
General comments |
|
|
American Council on Education |
American Association of Community Colleges |
Eligible entities; tax-exempt entities |
|
|
American Council on Renewable Energy |
Allison Nyholm |
Eligible entities; compliance and enforcement; documentation; alternative minimum tax |
|
|
American Fuel & Petrochemical Manufacturers |
Conner Brace |
Partnership eligibility; tax-exempt entities; progress expenditures |
|
|
American Petroleum Institute |
Aindriu Colgan |
Transferability of credits after partial use; estimated payments; project ownership; partnership special allocations; corporate alternative minimum tax |
|
|
American Public Power Association |
John Godfrey |
Partnership eligibility; eligible entities; time and manner of election |
|
|
American Public Transportation Association |
Ward W. McCarragher |
Tax-exempt entities; public transit eligibility |
|
|
Amicus Solar Cooperative |
Stephen Irvin |
Passive activity rules |
|
|
Amp Americas |
Grant Zimmerman |
Time and manner or elections |
|
|
Ample Inc. |
Ample Inc. |
General comments; technology and business model neutral regulations |
|
|
Anonymous |
Shariff Barakat - Akin Gump |
Project registration system; procedure for filing transfer election; assignability of credits; income recognition for discount |
|
| Atheva | Seth Feuerstein | Documentation; fraud and abuse; recapture; reasonable cause defense | Atheva Comments |
| Attorneys General of MA, CO, DE, IL, ME, MD, MI, NJ, NY, OR, RI, and DC; The CA Air Resources Board; and Ramsey Co., MN, Attorney |
Several | General Comments | Attorneys General of MA, CO, DE, IL, ME, MD, MI, NJ, NY, OR, RI, and DC; The CA Air Resources Board; and Ramsey Co., MN, Attorney Comments |
|
Avisen Legal, P.A. |
Jeremy Kalin |
Passive activity rules |
|
|
Baker Botts L.L.P. |
Barbara S. de Marigny |
Recapture; multi-year agreement; partnership allocations; gross income defined; partial Direct Pay; meaning of cash; 6418 transferee can elect 6417; corporate alternative minimum tax; coordination with 45Q(f)(3) transfers |
|
| Baker Tilly US LLP | Paul H. Dillon | Passive activity credits and Sec. 469 | Baker Tilly US LLP Comments |
|
Bank of America Corporation |
James Carlisle |
Partnership eligibility; time and manner for election; recapture; general comments |
|
|
Bingham Court Homeowners Association |
Time and manner for election |
||
|
Black Owners of Solar Services |
Ajulo E. Othow |
Partnership eligibility; eligible entities; tax-exempt entities |
|
|
Blue Rock Renewables |
Blue Rock Renewables |
More frequent than annual credits; estimated payments; corporation altenative minimum tax; gross income recoginition for discount; partnership eligibility; documentation |
|
|
bp America, Inc. |
Downey Magallanes |
Partnership special allocations |
|
|
Breakthrough Energy |
Breakthrough Energy |
Time and manner for election; recapture; credits acquired by election |
|
|
Brown and Caldwell |
Brown and Caldwell |
Tax-exempt bond financing; documentation; |
|
|
BurCell Technologies, Inc |
BurCell Technologies, Inc |
General comments; time and manner for election |
|
|
Business Roundtable |
Catherine Shultz |
General comments |
|
|
California Energy Storage Alliance |
Jin Noh, Grace Pratt |
Tax-exempt entities; recapture; documentation |
|
|
California Solar and Storage Association |
Joshua Buswell-Charkow |
Excessive payments; time and manner for election; documentation; recapture; alternative minimum tax |
|
|
Calpine Corporation |
Steven Schleimer |
Placed in service; transferability after Direct Pay |
|
|
Carbon Capture Coalition |
Carbon Capture Coalition |
Eligible entities; time and manner for election; recapture |
|
|
Carbon Utilization Research Council |
Shannon Angielski |
Partnership with tax-exempt partners eligibility; entity eligibility; estimated payments; time and manner for election; documentation |
|
|
Brian Kimball |
Eligibilty entities; tax-exempt entities; tax-exempt bonds; related party transferability; documentation |
||
|
Center for Biological Diversity |
Center for Biological Diversity |
Compliance and enforcement; documentation; environmental justice |
Center for Biological |
|
Center for Public Enterprise |
Center for Public Enterprise |
Conractors and subcontractors eligibility; partnerships with tax exempt partner; tax exempt entities; time and manner for election; documentation; publish IRS guidance |
|
|
City and County of Denver |
Jonathan Rogers |
Eligible entities; tax-exempt entities; tax-exempt bonds; capital leases; time and manner for election; documentation; compliance and enforcement |
|
|
City and County of Honolulu Office of Climate Change, Sustainability and Resiliency |
Matthew Gonser |
Time and manner for election; third-party ownership; calculation of direct pay percentages; energy community definition |
City and County of Honolulu Office of |
|
City of Austin |
Allison Wood |
Tax-exempt entities; depreciation coordination; compliance and enforcement; documentation |
|
|
City of Los Angeles |
Lauren Faver O'Connor |
Time and manner for election |
|
|
Clean Energy Districts of Iowa |
Andrew Johnson |
Tax-exempt entities |
|
|
Clean Energy Group |
Shelley Hudson Robbins |
Income tax liability requirement for individual taxpayers |
|
|
Clean Hydrogen Future Coalition |
Shannon Angielski |
Partnership eligibility; S corporation eligibility; eligible entities; estimated tax payments; penalties; time and manner for election; |
|
|
ClearPath |
Matthew Mallioux |
Eligible entities; transferability of credits after Direct Pay; related entities transferability; time and manner for election; documentation; excessive payments |
|
|
Climate Access Fund |
Climate Access Fund |
Tax-exempt entities; eligible entities |
|
|
Coalition for American Battery Independence |
Coalition for American Battery Independence |
Partnership eligibility; S corporation eligibility; eligible entities; time and manner for election; compliance and enforcement; documentation |
|
|
Connecticut Green Bank |
Connecticut Green Bank |
Time and manner for election; eligible entities; partnership eligibility; recapture |
|
|
Controlled Thermal Resources Holdings |
Controlled Thermal Resources Holdings |
Documentation; excessive credits; multi-year agreements |
|
|
Cook Inlet Region Inc. |
Cook Inlet Region Inc. |
Partnership eligibility; tax-exempt entities; ANC settlement trust eligibility; time and manner for election; income recognition for sale of credits |
|
|
Copacity, Inc. |
Copacity, Inc. |
Bonus payments eligible |
|
|
Corning, Inc. |
Tymon Daniels, |
Partnership eligibility; time and manner for election; alternative minimum tax |
|
|
Covanta and several local governments |
Paula Soos |
Progress expenditures; tax-exempt entities |
|
|
Creative Energies |
Income qualifications |
||
|
CubicPV Inc. |
CubicPV Inc. |
Time and manner for election; ramp-up period |
|
|
Cypress Creek Renewables |
Cypress Creek Renewables |
Partnership eligibility; definition of "cash"; transferability of credits |
|
|
Davis Polk |
Leslie J. Altus, |
Partnership eligibility; recapture |
|
|
Drax Group |
Ross McKenzie |
Estimated tax payments; transferability window; documentation; partnership eligibility; S corporation eligibility; |
|
|
Duke Energy Corporation |
Brian D. Savoy |
Transferee tax treatment |
|
|
Eavor Inc. |
Neil Ethier |
Community Choice Aggregations; eligible basis calculation; limitation on number of credits |
|
|
Edison Electric Institute |
Richard F. McMahon Jr. |
Gross income determination; tax-exempt entities; alternative minimum tax; partnership eligibility; recapture; documentation |
Edison Electric Institute Comments (1) |
|
Elevate |
Anne McKibbin |
Applicable entity qualification; third-party ownership; time and manner for election |
|
|
EnCap Investments L.P. |
Melissa Standley |
Partnership eligibility; tax-exempt entities; documentation and classification |
|
|
Energy Infrastructure Council |
Lori E. L. Ziebart |
Eligible entities; partnership eligibility; partnership special allocations; coordination with 45Q(f)(3) transfers |
|
| Energy Infrastructure Council |
Lori E. L. Ziebart |
Formal endorsement of: Navigator CO2, API, and Baker Botts comments | Energy Infrastructure Council Comments |
|
Energy Keepers, Inc. |
Brian Lipscomb |
Eligible entities - Indian tribal government; time and manner for election; tax-exempt entities; documentation |
|
|
Energy States Alliance |
Warren Leon, |
General comments |
|
|
Energy Tax Savers, Inc |
Charles Goulding |
Time and manner for election; tax-exempt entities; placed in service date; compliance and enforcement; documentation |
|
|
Energy Workforce & Technology Council |
Tim Tarpley |
General comments |
|
|
Energy Workforce & Technology Council |
Tim Tarpley |
General comments |
|
|
Enphase Energy |
Lisan Hung |
General comments |
|
| Equinor Wind US LLC |
Equinor Wind US LLC |
Partnership allocations and distributions |
Equinor Wind US LLC Comments |
|
Equipment Leasing and Finance Association |
Ralph Petta |
Passive activity rules; placed in service requirements |
|
|
Sam Ricketts |
Time and manner for election; partnership with tax-exempt partners |
||
|
Evergreen Renewables Inc. |
Ben Dickson |
Passive activity rules; tax-exempt entities; time and manner for election; documentation; compliance and enforcement; recapture |
|
|
Fairstead |
Fairstead |
Partnership with tax-exempt partners eligibility; entity eligibility; passive activity rules; recapture |
|
|
Fervo Energy Company |
Sarah Jewett |
Multiple transferees eligible; limit to number of transferees; Eligibility not limited to qualified investors |
|
|
Fidelis New Energy, LLC |
Fidelis New Energy, LLC |
Time and manner for election; documentation |
|
|
First Solar, Inc. |
Mark R. Widmar |
Facility-by-Facility eligibility; option for multiple 5-year Direct Pay periods; |
|
|
Form Energy, Inc. |
Nidhi Thakar |
Facility-by-facility eligibility |
|
|
Fort Wayne City Utilities |
Fort Wayne City Utilities |
Placed in service; partnership eligibility; excessive payments; S corporation eligibility; eligible entities; tax-exempt entities |
|
|
Fox, Jacob |
Fox, Jacob |
General comments |
|
|
Fuel Cell and Hydrogen Energy Association |
Frank Wolak |
Time and manner for election; compliance and enforcement; estimated payments; transferability of credits after partial use; corporate alternative minimum tax; excessive payments |
|
|
GAF Energy LLC |
Louis Feldman |
Passive activity rules; At-risk rules |
|
|
Game Changer Solar Corp. |
Jeffrey Paravano, |
Facility-by-facility eligiblity; multiple transferees |
|
|
GE Vernova |
Scott Strazik |
Partnership eligibility; multiple transferees eligible; facility-by-facility eligibility; time and manner for election |
|
|
General Motors Company |
Omar A. Vargas |
Procedures following 5-year Direct Pay period; eligible entities; partnership eligibility; documentation; recapture; compliance and enforcement |
|
|
GHD |
GHD |
Time and manner for election; Placed in service date |
|
|
Global Infrastructure Investor Association |
Lawrence Slade |
Time and manner for election; tax-exempt entities |
|
|
Government Finance Officers Association |
Emily Brock |
Eligible entities; political subdivision definition; time and manner for election |
|
|
GRID Alternatives |
GRID Alternatives |
Time and manner for election; documentation; excessive payments |
|
|
Growth Energy |
Chris Bliley |
Time and manner for election; procedures following 5-year Direct Pay period; estimated payments; excessive payments |
|
|
Hanwha Q Cells USA Inc. |
Andy Munro |
Eligible entities; documentation; time and manner of election |
|
|
Hennepin County, Minnesota |
Kareem Murphy |
Political subdivision meaning; tax-exempt bonds; time and manner for election, place in service definition |
|
|
Henson, Jesse Wolf Corsi |
Henson, Jesse Wolf Corsi |
Tax-exempt entities |
|
|
Herron, Brendan |
Herron, Brendan |
Tax-exempt entities; recapture; documentation; compliance and enforcement |
|
|
Highland Electric Fleets, Inc. |
Brendan Beasley |
Partnership eligibility; S corpration eligibility; definition of "portion" of credit for transferability |
|
|
Hyundai Motor Group |
Robert R. Hood |
Eligible entities; transferability of credits after partial use; partnership eligibility; carryback and carryforward; documentation; excessive payments |
|
|
Indiana Municipal Power Agency |
Jack F. Alvey |
Tax-exempt entities; time and manner for election |
|
|
Industrial Energy Consumers of America |
Industrial Energy Consumers of America |
Multiple transferees eligible; recapture; compliance and enforcement |
|
| Industrial Energy Consumers of America | Industrial Energy Consumers of America | Transferability; recapture; compliance and enforcement | Industrial Energy Consumers of America Comments |
|
Jackel, Monte |
Jackel, Monte |
Partnership allocations |
|
|
Jewish Federations of North America |
Stephan O. Kline |
Tax-exempt entities, time and manner for election; compliance and enforcement |
|
|
Multiple signatories |
General comments |
||
|
Just Solutions Collective |
Multiple signatories |
Resubmitted with identical content but additional signatories |
|
|
Keweenaw Bay Indian Community |
Kim Klopstein |
Eligible entities- Indian tribal government; time and manner for election; partnership eligibility; documentation |
Keweenaw Bay Indian |
|
Large Public Power Council |
Large Public Power Council |
Political subdivision meaning; tax-exempt bonds; excessive payments, place in service definition; safe harbor for penalties |
|
|
LG Group |
LGES |
Time and manner for election |
|
|
Lightsource bp |
Alyssa Edwards |
Recapture; partnership eligibility; S corporation eligibility; lease pass-through election |
|
|
Lummi Indian Business Council |
Anthony Hillaire |
Tribal entities; time and manner for election; compliance and enforcement |
|
|
Maine AFL-CIO |
Maine AFL-CIO |
Time and manner for election |
|
|
Maine Labor Climate Council |
Maine Labor Climate Council |
Time and manner for election |
|
|
Marin Clean Energy |
Nathaniel Malcolm |
Community Choice Aggregations; documentation; tax-exempt bonds; related party sales |
|
|
McDermott Will and Emery |
Phil Tingle |
Time and manner for election; eligible taxpayer transferee; 2022 eligibility |
|
|
Meyer Burger Americas |
Ardes Johnson |
Related party sales; compliance and enforcement; facility-by-facility eligibility; time and manner for election |
|
|
Moapa Band of Paiute Indians |
Laura Parry |
Time and manner or election; partnership eligibility; documentation |
|
|
Molina Healthcare |
George J. Figueroa |
Time and manner for election; excessive payments; compliance and enforcement; safe harbors for penalties |
|
|
Moss Adams LLP |
Moss Adams LLP |
Time and manner for election; documentation; eligible entities; Indian tribal governments; partnership eligibility; S corporation eligibility |
|
|
Moye White LLP |
Allen N. Bradley |
Eligible entities; passive activity rules |
|
|
NAFA Fleet Management Association |
Bill Schankel |
Time and manner for election |
|
| Nancy Kuhn | Nancy Kuhn | Applicable entity definition; unrelated business taxable income; applicable taxpayer definition |
Nancy Kuhn Comments |
|
Nareit |
Tony M. Edwards |
Partnership eligibility; general comments |
|
|
National Grid North America Inc. |
Bryan Marcelino |
Partnership eligibility and related allocation questions |
|
|
National Hydropower Association |
Michael Purdie |
Time and manner for election |
|
|
National Multifamily Housing Council and other real estate trade associations |
National Multifamily Housing Council |
Partnership eligibility; tax-exempt entities |
National Multifamily Housing |
|
National Outdoor Leadership School |
Jonathan Williams |
Time and manner of election |
|
|
National Venture Capital Association |
National Venture Capital Association |
Time and manner for election; recapture; safe harbor for penalties; documentation |
|
|
Navigator CO2 |
Jeff Allen |
Eligible taxpayers coordination with Section 45Q |
|
|
Nelson, Elizabeth |
Nelson, Elizabeth |
Passive activity rules |
|
|
New Mexico Tax Credit Alliance |
Ethan Epstein |
Time and manner for election; Carryback and carryforward; eligible taxpayer transferee; Passive activity rules; Income recognition for discount; tax-exempt entities; documentation; |
|
|
New Mexico Tax Credit Alliance |
Ethan Epstein |
Prohibition on transfer |
|
|
NextEra Energy |
NextEra Energy |
Partnership eligibility; special allocations of credit; tax-exempt entities; excessive payments; AMT coordination; recapture; facility-by facility eligibility; compliance and enforcement; affiliated group treatment |
|
|
Northern California Power Agency |
Randy S. Howard |
General comments |
|
|
Novogradac Renewable Energy Working Group |
Tony Grappone |
Excessive payments; partnership eligibility; S corporation eligibility; eligible entities; documentation; compliance and enforcement; recapture; time and manner for election |
|
|
NYU School of Law Institute for Public Integrity |
Meredith Hankins |
General comments |
|
|
Occidental Petroleum |
Jennifer L. Buchanan |
Facility-by-facility eligibility; time and manner for election; excessive payments; recapture; documentation |
|
|
Oceti Sakowin Power Authority |
Jonathan Canis |
Tax-exempt eligibility; definition of "applicable credit" |
|
|
OCI N.V. |
OCI N.V. |
Corporation alternative minimum tax |
|
|
Orsted Wind Power North America LLC |
Peter Allen |
partnership with tax-exempt partner eligibility; corporate alternative minimum tax |
|
|
Panasonic Corporation of North America |
Jeffrey Werner |
Time and manner for election; amount of credit calculation; entity eligibility; excessive payments; facility-by-facility eligibility |
|
|
Paul Hastings LLP |
Paul Hastings LLP |
Non-US person eligibility; compliance and enforcement; recapture; partnership eligibility; S corporation eligibility; excessive credits |
|
|
Pechanga Western Electric |
Pi-Ta Pitt |
Eligible entities- Indian tribal government; time and manner for election |
|
|
Plug Power Inc. |
Plug Power Inc. |
Third-party verification; documentation; safe harbor |
|
|
PRBA - The Rechargeable Battery Association |
George A. Kerchner |
Option for multiple 5-year Direct Pay periods |
|
|
Rainbow Energy Center, LLC |
Rainbow Energy Center, LLC |
Time and manner for election; eligible entities; partnership eligibility; S corporation eligibility; documentation |
|
|
Renewable Fuels Association |
Geoff Cooper |
Time and manner for election; facility-by-facility eligibility |
|
|
Renewable Thermal Collaborative |
Renewable Thermal Collaborative |
Time and manner of election; restrictions on transfers; compliance and enforcement; documentation |
|
|
Resources for the Future |
Billy Pizer, |
General comments |
Resources for the Future Comments (1) |
|
Rincon Band of Luiseño Indians |
Bo Mazzetti |
Eligible entities- Indian tribal government; time and manner for election; placed in service |
|
|
Rivian Automotive, LLC |
Rivian Automotive, LLC |
Recapture |
|
|
RMI |
RMI |
Partnership with tax-exempt partner eligibility; utility normalization; recapture; transferee indemnification |
|
|
Sacramento Municipal Utility District |
Lawrence Luong |
Tax-exempt bond financing; documentation; time and manner for election |
|
|
Salt River Project |
Aidan J. McSheffery |
Time and manner for election; documentation |
|
|
Seneca farms biochar |
Seneca farms biochar |
General comments |
|
|
Shade, Matt |
Shade, Matt |
Tax-exempt entities |
|
|
Siemens Gamesa Renewable Energy, Inc. |
Siemens Gamesa Renewable Energy, Inc. |
Eligibile entities; transferability after Direct Pay; non-consecutive years use of credits; facility-by-facility elegibility |
|
|
Snell & Wilmer LLP |
Marc Shultz |
eligible entities - political subdivision |
|
|
Solar Energy Industries Association |
Sean Gallagher |
Credit amount calculation; eligible entities; safe harbor for penalties; recapture |
|
|
Solar Energy Manufacturers for America |
Solar Energy Manufacturers for America |
Transferability after Direct Pay; partnership eligibility; S corporation eligibility; eligible entities; time and manner for election; documentation |
|
|
Solar One |
Kate Selden |
Tax-exempt entities; time and manner for election; |
|
|
Solar United Neighbors of the Institute for Local Self-Reliance |
Solar United Neighbors of the Institute for Local Self-Reliance |
Eligible entities; pre-approval options; time and manner for election; tax-exempt entities; applicability in Puerto Rico/U.S. territories |
Solar United Neighbors of the |
|
Solstice Initiative |
Solstice Initiative |
Time and manner for election |
|
|
Sonoma Clean Power Authority |
Sonoma Clean Power Authority |
Community Choice Aggregations; documentation |
|
|
Southern Alliance for Clean Energy |
Southern Alliance for Clean Energy |
TVA and elective payments |
|
| States of: Colorado, Connecticut, Maine, and Pennsylvania | Will Toor, Katie Dykes, Hannah Pingree, Ramez Ziadeh |
Applicable entity definition; applicable taxpayer definition |
States of: Colorado, Connecticut, Maine, and Pennsylvania Comments |
|
Stellantis |
Shane Karr |
Time and manner for election; documentation; compliance and enforcement; carryback and carryforward |
|
|
Stephen Cox |
Stephen Cox |
Carryback rules |
|
|
Strugar, Michael |
Strugar, Michael |
Time and manner for election; documentation; carryback and carryforward; passive activity loss rules; gross income defined for discount |
|
|
Sunnova Energy International, Inc. |
David Skillman |
Recapture exposure a matter for agreement; in absence of agreement transferor bears |
|
|
SunPower Corporation |
Suzanne Leta |
General comments |
|
|
Sunrun Inc. |
Shirley Chin |
Tax-exempt entities; passive loss rules; pass-through credits; partnership eligibility; definition of "cash"; alternative minimum tax; definition of “taxpayer” to include tax-exempts; transferees can elect 6417; partnership allocations; guarantee of credits |
|
|
Sunstone Credit |
Kragie, Alex |
Time and manner for election; documentation |
|
|
Sustainable Westchester |
Carmen Santos |
Private letter ruling eligible; tax-exempt entities |
|
|
Tax Executives Institute, Inc. |
Ben Shreck |
Partnership eligibility; eligible entities; Alaska Native Corporations eligibility; time and manner for election |
|
|
Taxpayer for Common Sense |
Steve Ellis |
Compliance and enforcement; documentation; recapture |
|
|
Tennessee Valley Authority |
Edward C. Meade |
Applicable entity qualification |
|
|
Tesla, Inc. |
Hasan Nazar |
time and manner for election; revocation of election; compliance and enforcement; transfer of credits after partial use |
|
|
The Hopi Tribe |
Timothy L. Nuvangyaoma |
Time and manner for election; documentation; Indian tribal government; partnership eligibility |
|
|
The National Rural Electric Cooperative Association |
Russell D. Wasson |
Tax-exempt entities; time and manner of election; partnership eligibility; S corporation eligibility; placed in service definition; |
The National Rural Electric |
|
The Real Estate Roundtable |
Jeffrey D. DeBoer |
Partnership eligibility; tax-exempt entities; recapture |
|
|
Twin Transit |
Joe Clark |
General comments |
|
|
Urban Ingenuity |
David Godschalk |
Partnership eligibility; multiple transferees eligible |
|
|
Utah Associated Municipal Power Systems |
Utah Associated Municipal Power Systems |
General comments |
|
|
Vernon, Walt |
Vernon, Walt |
||
|
Vernon, Walt |
Vernon, Walt |
Application process; recapture; depreciation |
|
|
Vernon, Walt |
Vernon, Walt |
General comments |
|
|
Volkswagen Group of America, Inc. |
Anna-Maria Schneider |
BEAT characterization of benefits |
|
|
Walker River Paiute Tribe |
Amber Torres |
Eligible entities; documentation, time and manner for election |
|
|
Windustry |
Lisa Daniels |
Time and manner for election; documentation |
|
|
Winona Area Public Schools ISD #0861 |
Annette Freiheit |
Eligible entities; tax-exempt entities |
|
|
Winthrop & Weinstine PA |
Norm Jones |
Eligible entities; partnership eligibility; recapture; carryback and carryforward; income recognition for discount |
|
|
Wisconsin Building Trade Council |
Wisconsin Building Trade Council |
Time and manner for election |
|
|
Wolfspeed, Inc. |
Bradley D. Kohn |
Compliance and enforcement; transferability; excessive payments; passive activity rules; time and manner of election |
|
|
World Resources Institute |
World Resources Institute |
Tax-exempt entities; time and manner of election |
|
|
Zekelman Industries |
Michael Graham and Angela Miu |
Credit errors; multiple transferees eligible |
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