Greg Jenner

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Greg Jenner advises and represents clients on a wide range of tax transactions and issues. He heads the firm’s Washington, D.C., office, is a partner in the tax practice group and is a past co-chair of the firm’s energy team. He has had broad experience in virtually all federal tax matters, with particular focus on planning and implementing complex tax-related transactions, partnerships and joint ventures, and at Stoel Rives has increasingly focused on planning for renewable energy projects. Greg has ten years of combined experience at Treasury and on Capitol Hill. This experience provides him with unique and invaluable insights into legislative, tax policy, and budget processes, which in turn translates into value for the firm’s clients. Greg  speaks nationally on renewable energy tax planning, agriculture tax issues, and tax and budget policy.

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Renewable + Law Blog Launches New Responsive Design and Enhanced Reader Features

Dear Renewable + Law Blog readers. Chances are you’ve noticed our new – and improved – appearance. We first launched our blog in 2008, pledging to keep you updated on major policy and legal developments impacting the renewable energy industry. That commitment hasn’t changed, but technology certainly has. It was still a desktop- and RSS-dominated … Continue Reading

Blog: FERC Chair Jon Wellinghoff to Join Stoel Rives

Our firm today announced that Jon Wellinghoff, Chair of the Federal Regulatory Commission (FERC), will join Stoel Rives LLP upon completion of his service at FERC. As many of our readers will recall, Jon submitted his resignation to the President on May 28, 2013. No date has been announced for his departure from FERC. For … Continue Reading

IRS Likely to Supplement “Beginning Construction” Guidance

As most of you are aware, Congress in the "American Taxpayer Relief Act of 2012" eliminated the "placed in service" deadline for purposes of the renewable energy tax credits.  In its place, Congress required for purposes of the production tax credit (section 45) and the elective investment tax credit (section 48), that taxpayers "begin construction" … Continue Reading

IRS Issues Clarification Regarding “Binding Written Contract” in its “Start of Construction” Guidance for PTC or ITC Energy Credits

As we originally noted, the IRS guidance issued April 15 regarding the "start of construction" requirement for energy projects to qualify for PTC or ITC contained a "big surprise" regarding its definition of a binding contract. Unlike previous incentive programs, the guidance provided that contracts that limit damages to a specified amount, such as by … Continue Reading

Phase II – 48C credits

As you may have heard, the IRS and DOE have announced a second allocation of "Advanced Energy Project Tax Credits" – also known as 48C credits.  The 48C credit was enacted as part of the stimulus bill (ARRA) in 2009 and the first allocation was made in 2010.  Phase II is being held because a … Continue Reading

Congress Passes Extension and Modification of Production Tax Credit

News reports have already alerted people to the fact that Congress has extended the Production Tax Credit ("PTC") for wind as part of its agreement to avoid the fiscal cliff. The bill – named the American Tax Relief Act of 2012 – extended the sunset date for wind through December 31, 2013. This extension gives … Continue Reading

Economists Weigh in on the PTC Extension

Against the backdrop of election year politics and consideration of extension or elimination of the Production Tax Credits (PTCs), the Congressional Research Service (CRS) issued a report last week entitled, “U.S. Renewable Electricity: How Does the Production Tax Credit (PTC) Impact Wind Markets?” This report examines the possibility of an extension of the PTC, and … Continue Reading

Further update on Expiring Provisions

As I mentioned in my post yesterday, sometimes a chairman’s mark will change just before the committee marks up legislation.  Chairman Baucus’s did.  Here is a description of the now-included PTC/ITC proposal: Description of Proposal  The proposal extends and modifies the expiration dates for the renewable electricity production credit and the 30-percent investment credit in … Continue Reading

Follow up – Baucus and Hatch strike deal on expiring provisons

Earlier today, I reported that Senators Baucus and Hatch had agreed on a proposal to extend a package of expiring provisions.  Details of that package have now been released here: Unfortunately, it appears that extension of the PTC was not included.  This does not preclude the Senate Finance Committee from adding it during its … Continue Reading

Possible Agreement on Extension of Tax Provisions, including PTC

Senators Max Baucus and Orrin Hatch, chairman and ranking member respectively, of the US Senate Finance Committee, have just announced that they have reached agreement on legislation to extend certain expiring tax provisions.  The bill will be marked up by the Finance Committee on August 2. The details of the proposal have not been announced.  … Continue Reading

President Proposes Permanent PTC Extension

On Wednesday, February 22, the White House and the Department of Treasury issued a report entitled “The President’s Framework for Business Tax Reform.”  Among other proposals for reforming the way U.S. businesses are taxed, the report calls for a permanent extension of the Production Tax Credit (“PTC”) for renewable energy projects.  In addition, the President’s … Continue Reading

House Passes Senate tax bill

As many of you have heard, this morning the House of Representatives passed the Senate compromise tax bill by a vote of 277-148.  The bill now goes to the President for his signature. For the renewables industry, this is extremely good news.  The bill extends the deadline for beginning construction for the section 1603 grant … Continue Reading

Tax bill update

As some of you may have heard, the Senate today passed its version of the tax compromise by a vote of 81-19.  The bill includes an extension of the deadline in section 1603 for beginning construction through 2011.  The size of the majority is a strong signal to the House that the Senate may not … Continue Reading

Update on Tax Bill Negotiations

For those of you interested in the machinations in Congress over the tax cut extensions, especially concerning renewable energy, here is the latest: Yesterday, the Senate released what it termed a "final compromise" bill.  That bill should be voted on in the Senate very soon.  It reflects negotiations within the Senate and between the Senate … Continue Reading

Reid-Baucus Tax Bill

Today, Majority Leader Harry Reid and Senate Finance Committee Chair Max Baucus released their proposal for a middle class tax cut.  Although far from the final product, the bill gives us some insight into thinking on the Senate side. From a renewable energy standpoint, the most important proposal is a one-year extension of the ITC … Continue Reading

Future of 1603

Updated at bottom The following is a question I received, which I thought I would answer on the Blog: Greg, as the expiration for the 1603 grant gets closer, two questions? 1) what are the chances of the grant being extended and 2) what are the modifications to the 1603 that you see coming January … Continue Reading

Proposed Legislation to Limit ITC Grants for Renewable Projects

Proposed legislation in the Senate would greatly limit the effectiveness of the grant in lieu of tax credits for renewable energy projects under section 1603 of the American Recovery and Reinvestment Act. The section 1603 grant currently applies to renewable energy projects, such as wind, solar, geothermal and biomass, that are placed in service before … Continue Reading

Stoel Rives Clients Receive Huge Tax Credit Awards

Stoel Rives would like to congratulate REC Silicon and SolarWorld on their awards of tax credits by the IRS and DOE. These two companies, combined, received over 10 percent of all the tax credits awarded nationwide under section 48C of the tax code. On Friday, January 8, the Department of Energy awarded to 183 companies … Continue Reading

Technical Correction to Section 1603 Grant May Loosen Rules for Investment by Tax Exempts

  On December 2, House Ways & Means Chairman Rangel and Ranking Member Camp introduced a tax technical corrections bill (H.R. 4169).  We will likely see an identical version introduced in the Senate very soon. Included among the technicals are changes to the Grant in Lieu of ITC under section 1603 of ARRA.  The most … Continue Reading

No Preliminary Approval for ITC Grants

In recent days, there have been rumors circulating that Treasury would issue "pre-approvals" for ITC grants in cases where construction begins in 2009 or 2010 but the project is not placed in service before 2011.  You will recall that projects may still qualify for the ITC grant in those cases if they meet the placed … Continue Reading