Overview
IRS No Longer Issuing New Clean Renewable Energy Bonds: Notice 2018-15 states that the IRS will no longer be processing applications for, or issuing allocations of, new clean renewable energy bonds (New CREBs) under section 54C. Section 54C authorized the issuance of up to $2.4 billion (volume cap) of New CREBs for qualified renewable energy facilities. Section 54C was repealed by the 2017 tax reform legislation (P.L. 115-97), effective for bonds issued after December 31, 2017.
EU Launches Website on Impact of Brexit on Customs and Tax Matters: The European Commission Taxation and Customs Union has established a website providing information about the impact of the United Kingdom’s (UK) withdrawal from the European Union (EU) with respect to customs and tax matters. According to the website, “[p]reparing for the [UK’s] withdrawal in the area of customs and taxation is not just a matter for EU and national authorities but also for companies and individuals trading with the United Kingdom.” The page will be updated regularly with new information.
Miscellaneous Guidance:
Revenue Procedure 2018-7, released on January 23, has been renumbered to revised Revenue Procedure 2018-12. Revenue Procedure 2018-12 provides methods that taxpayers may use to value certain stock received by a target corporation’s shareholders in a potential reorganization for purposes of determining whether the continuity of interest requirement under Treas. Reg. § 1.368-1(e) is satisfied. It also makes corrections to the original guidance, including to section 3 (describing transactions to which the revenue procedure applies), section 4 (setting forth the safe harbor valuation methods and measuring periods) and section 6 (describing the scope and effect of the revenue procedure).