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Threading the Needle: Pillar Two and the IRA’s Green Energy Credits

Cross-border Tax Talks

CHAPTER

Equity Partner Investment Structures

Administrative guidance provided relief for what they referred to as equity investment flow through election and qualifying flow through tax benefits. So before we even dive into those elections, what are equity partner investment structures? Right. You first need that before you can qualify for the qualifying flowthrough tax benefits or make the election. Yes. And so the concept of an equity method partnership is essentially just what I described. There's a partnership, you've got an investor who is getting the benefit of the credits,. They account for that for GAP purposes under the equity method. The credits all flow to them.

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