The IRS has issued a new revenue procedure, Rev. Proc. 2023-15, providing a safe harbor method of accounting for natural gas transmission and distribution property repairs, maintenance, replacements, and improvements. This new method allows taxpayers to classify these costs as either capital or deductible expenditures, providing clear and bright-line rules to reduce the burden of compliance.
Read MoreOn October 15, the IRS issued PLR 202141001 for regulated electric utilities. In its ruling, the IRS reiterated earlier assertions that the net deferred tax asset (DTA) related to the cost of removal (COR) is not subject to normalization, but also added clarification that the deferred tax liability (DTL) and DTA from the salvage value is subject to normalization rules.
Read MoreThe Internal Revenue Service (IRS) has issued several private letter rulings (PLR) in recent months clarifying the relationship between solar power generation equipment and public utility companies. The main focus is defining whether or not generation equipment with energy pricing based on monthly fees can be treated as public utility property. The designation of generation equipment as public utility property has several important implications, all of which impact how utilities treat the property for tax purposes.
Read MoreOn August 14, 2020, the Internal Revenue Service (IRS) issued PLR 202033002 to address outstanding ruling requests on the application of the Section 168 normalization rules to cost of removal (COR). The IRS concluded that the net deferred tax liability (DTL) created by COR is not protected by the normalization rules but did not provide guidance on the actual implementation of the ruling’s conclusions.
Read MoreOn August 14, 2020, the Internal Revenue Service (IRS) issued Revenue Procedure 2020-39 to clarify normalization requirements following the corporate tax rate reduction provided in the Tax Cuts and Jobs Act (TCJA). Though this Revenue Procedure addressed several open questions posed by the utility industry, in some regards, the publication raised more questions than it answered.
Read MoreOn May 7, 2019, the IRS released Notice 2019-33 which formally announced the agency’s intent to issue additional guidance regarding the normalization requirements of excess deferred income taxes which resulted from the decrease in the corporate income tax rate.
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