David S. Lowman, Jr.

IRS Interprets Special Exception Applicable to Renewable Energy Projects in Puerto Rico and Other U.S. Possessions
Timothy L. Jacobs,Laura Ellen Jones,David S. Lowman, September 21, 2011
The IRS recently released a private letter ruling that a renewable energy project located in a U.S. possession qualified for the investment tax credit and accelerated depreciation. The ruling addresses a key legal issue for renewable energy projects, namely whether a project owned by a U.S....

IRS Declines Appeal of Street Light Issue in PPL Case: Assets Fall into Residual Class for Depreciation Unless Specifically Included in Another Asset Class
Mark B. Bierbower,Timothy L. Jacobs,David S. Lowman,Richard Edward May, July 11, 2011
On July 28, 2010, in PPL Corporation & Subsidiaries v. Commissioner of Internal Revenue, 135 T.C. No. 8, the United States Tax Court held that street light assets owned and depreciated by an electric utility do not constitute assets used in the distribution of electricity for sale (20-year...

Treasury Releases Guidance Describing Process for Evaluating Cost Basis for Treasury Grant Purposes
Timothy L. Jacobs,Laura Ellen Jones,David S. Lowman, July 11, 2011
On June 30, 2011, the Treasury Department released guidance describing the process for evaluating the cost basis of projects qualifying for a Treasury Grant under Section 1603 of the American Recovery and Reinvestment Act. The guidance “outlines the process used by the Section 1603 team to...