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 …
Cooperative Posts
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 …
Guest Post: Declassified Report Eyes Grid Security
The U.S. electric grid is vulnerable to terrorist attacks that could cause much more damage to the system than natural disasters such as Hurricane Sandy, according to a recently declassified report prepared for the U.S. Department of Homeland Security by …
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 …