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Articles by Mark Christy
A lifetime resident in support of Mark Orgill for City Council
My friends know that if I ever refer the name of a plumber, a handyman or a painter, it means I have tremendous confidence in the quality of their work and their personal integrity. I don’t want it to come back and bite me. Similarly, I don’t often make public City Council endorsements. The Council Members make numerous important decisions each week, some of which I will disagree with, but that’s just the nature of the job.
Court Throws Out Notice 2025-42 – 5% Safe Harbor is Back for Wind and Solar
Why it matters A federal court has vacated IRS Notice 2025-42, potentially restoring the 5% safe harbor as a valid method for establishing beginning of construction before the July 4, 2026, deadline for wind and solar projects.
Energy Tax Update: New Material Assistance/FEOC Guidance Released | JD Supra
On Thursday, February 19 Orrick’s Energy Tax Team hosted a webinar discussing IRS Notice 2026-15. The Notice, which was released on February 12, provides interim guidance on the application of restrictions related to prohibited foreign entities (PFEs) for energy credits under Sections 45X, 45Y and 48E. It also outlines interim safe harbors, definitions and compliance requirements for taxpayers seeking to claim clean energy credits, while ensuring compliance with new PFE restrictions.
IRS Issues Guidance on Beginning of Construction for Wind and Solar Facilities Under the OBBBA | JD Supra
On August 15, 2025, the IRS and the Treasury Department released Notice 2025-42 (the Notice), providing critical guidance on the beginning of construction requirements for wind and solar facilities in light of the One Big Beautiful Bill Act (the OBBBA) and Executive Order 14315 (the Executive Order).
Client Alert: Reconciliation Bill Passes House: Detailed Analysis of Energy Tax Credit Changes | JD Supra
Introduction The House of Representatives has passed a sweeping tax reconciliation bill that makes significant changes to the U.S. energy tax credit regime. The bill, as originally reported out of the House Ways and Means Committee, proposed accelerated phaseouts, new transferability restrictions, and stringent foreign entity limitations for a range of energy credits. At the floor vote, substantial amendments were proposed and incorporated into the bill that will now be considered by the Senate.
Final Regulations Released for the Clean Electricity Low-Income Communities Bonus Credit Program | JD Supra
The U.S. Department of the Treasury and the Internal Revenue Service have published final regulations concerning the low-income communities bonus credit program under Section 48E(h) of the Internal Revenue Code of 1986, as amended (the Code), and related procedural guidance. Introduced by the Inflation Reduction Act of 2022, this program allows the Secretary of the Treasury to establish the program for 2025 and future years.
New IRS Guidance on Domestic Content Bonus Credit | JD Supra
The U.S. Department of the Treasury and the Internal Revenue Service have issued Notice 2025-08 (the “First Updated Elective Safe Harbor”), offering new guidance on the bonus credit for projects using domestically produced property, known as the “DC Adder,” and modifying the safe harbor provided in Notice 2024-41 (the “New Elective Safe Harbor”).
Tech-Neutral Credits Final Regulations Released for Clean Electricity Production | JD Supra
The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) have released final regulations for two new tax credits under the Internal Revenue Code (Code), established by the Inflation Reduction Act (IRA): the clean electricity production credit under Section 45Y (Section 45Y PTC) and the clean electricity investment credit under Section 48E (Section 48E ITC). Together, these are known as the Tech-Neutral Credits.
Treasury and IRS Release Guidance on Clean Fuel Production Credit | JD Supra
The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released a notice of intent to propose regulations and a notice providing the annual emissions rate table for the Clean Fuel Production Credit under Section 45Z of the Internal Revenue Code (45Z credit) outlining methodologies for determining the lifecycle greenhouse gas emissions of fuel.
Section 45V Clean Hydrogen Tax Credits: Final Regulations Released | JD Supra
The U.S. Department of the Treasury and Internal Revenue Service (IRS) have released final regulations or tax credits for the production of clean hydrogen under Section 45V of the Internal Revenue Code. The industry has eagerly awaited the final regulations, which provide more defined guidance and greater investment certainty. Key Dates Placed in service: The 45V credits are available for facilities that are placed in service after December 31, 2022, and that begin construction before 2033.
Final Treasury Regulations Issued Governing Transfers Of Renewable Energy Tax Credits
On April 25, 2024, IRS and Treasury issued final regulations under Code Section 6418 (the Final Regulations) governing the transfer and monetization of certain Tax Credits, as permitted under the Inflation Reduction Act of 2022 (P.L. 117-169) (the IRA). The Final Regulations substantially conform to the proposed regulations that were released on June 14, 2023 (the "Proposed Regulations"), with only minimal changes.
IRS Victory In YA Global V. Commissioner: A Cautionary Tale
On November 15, 2023, the Tax Court released its opinion1in YA Global v. Commissioner and, among other conclusions, held that YA Global Investments LP, a Cayman Islands limited partnership (YA Global), was engaged in a U.S. trade or business for purposes of Code Section 864. YA Global was a hedge fund that focused on equity-related lending transactions with convertible instruments and standby equity distribution arrangements (SEDAs).
No Reason For Treaty Investor's Right To Terminate Manager Without Cause
United States: No Reason For Treaty Investor's Right To Terminate Manager Without Cause 12 August 2021 by Mark R. Christy (Chicago) , Dennis J. Kelly (Chicago) and Andrea S. Herman (Chicago) Winston & Strawn LLP To print this article, all you need is to be registered or login on Mondaq.com.
Recent Tax Developments Affecting Alternative Energy Transactions: Extension of Continuity and Five Percent Safe Harbor Under IRS Notices | Lexology
In response to the economic disruptions that have resulted from the COVID-19 pandemic, on May 27, 2020, the IRS issued Notice 2020-41 to extend the continuity and five percent safe harbor under previously issued IRS guidance relating to solar and wind projects.
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