IRS Energy Direct Pay Rules Take Some Projects 'Off the Table'
Anne Loomis, a partner in Troutman Pepper's Tax Practice Group, was quoted in the June 30, 2023 Bloomberg Law article, " IRS Energy Direct Pay Rules Take Some Projects 'Off the Table'."
"If they have to own it directly, they need to be taking on all of the operational risk," said Anne Loomis, a partner at Troutman Pepper. "I think for some tax-exempt entities, that’s not a risk that they’re able to take on."
...
Treasury offers an alternative for exempt and taxable organizations: joint ownership. This is a much less efficient way of owning and operating a project than a partnership would be, Loomis said.