IRS Will Share Taxpayer Information to Detect Section 1603 Wrongdoing

In a Chief Counsel Advisory, the IRS discussed whether it had authority to share confidential taxpayer information with the Treasury Department’s Office of Fiscal Assistant Secretary (“OFAS”).  In discussing the restrictions on such disclosure, the advisory also identified key compliance …

Takeover Rights In Renewable Energy Project Development

Renewable projects are typically complex and require substantial amounts of capital.  Some parties may bring expertise; others may bring equipment components; while others may bring funds.  In any event, these multiple parties will have agreements — called development agreements — …