American Bar As’n and DC Bar Hear Viva Hammer Talk on Dodd-Frank

Tax is the sleeping tiger in Dodd-Frank; Viva Hammer led a discussion with Stephen Larson and K Scott Brown of Financial Institution and Products at the IRS Chief Counsel and John Newton of Prudential Financial in December 2010 for the DC Bar, and with Stephen Larson and Phoebe Mix of Financial Institution and Products at the IRS Chief Counsel at the American Bar Association in Boca Raton, FL in January 2011.2010-12 DC Bar 1256 Dodd-Frank, 2010-12 DC Bar 1256, 2011 ABA FL Marking Without Section 1256

Alternative Energy Gets a Second Wind

Viva Hammer comments tax incentives for the alternative energy industry.  The industry relies heavily on federal tax incentives for viability, particularly thesection 45 production tax credit (PTC). The IRS stymied alternative energy development when it published Rev. Proc. 2007-65, which was intended toprovide reassurance to wind energy partnerships claiming the PTC. After receiving comments frommembers of the alternative energy industry, the IRS relaxed several stringent requirements in the revenueprocedure to be more consistent with standard industry practices. Viva Hammer’s report discusses the history of the PTC, the IRS’s initial attempt at creating a safe harborfor wind energy partnerships in Rev. Proc. 2007-65,and revisions to the safe harbor in Announcement2009-65, which addressed the concerns of the windenergy industry. It also looks at the future of windenergy and what steps are needed to promote its growth. TNT 2010-11-22 Wind