IRS Revokes Potentially Beneficial Ruling for Renewable Energy Developers

A prior blog post discussed a private ruling by the service regarding the allocation of purchase price among the assets of a renewable energy developer.  Attorney David R. Cook discussed the ruling in a webinar on PPA taxation and recommended …

AHC Cooperative Tax Brief: Mutual Ditch and Irrigation Company Denied Exemption

The Service recently denied exemption to an organization that sought exemption under Section 501(c)(12) as a mutual ditch and irrigation company.  The organization failed to satisfy several requirements for exemption under Section 501(c)(12).  The ruling provided an insight into the

AHC Cooperative Tax Brief: Proposed Amendment to Section 501(c)(12) for Water Companies

On November 29, 2012, Senator Udall of Colorado submitted a bill to amend Section 501(c)(12) as it relates to mutual ditch and irrigation companies.  The bill would (i) modify the Member Income Test by exempting certain income and (ii) codify …