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The UK Football Governance Bill: Impact on ownership
The UK Football Governance Bill (the Bill), reintroduced by the current Labour government in 2024, marks a significant shift in the regulation of English football.
On Feb 24, the US Court of Appeals for the Federal Circuit released its decision in Ampersand Chowchilla Biomass LLC v. US, in which the court considered when a power generation project is placed in service for federal income tax purposes.
The case arose in the context of a now-lapsed cash grant program, created as part of the American Recovery and Reinvestment Act in 2009 to increase investment in domestic clean energy production. Under the program, the US Department of the Treasury provided a cash grant of 30% of eligible basis in lieu of tax credits.
The rules for the grant were supposed to mimic the rules of the investment tax credit under Section 48 of the Internal Revenue Code. Accordingly, although the cash grant program is long over, these cases have implications for tax planning for today's power generation projects.
In the Ampersand case, the court found two California facilities were ready and available to produce and sell electricity in 2008 when the facilities were synchronized to the transmission grid, began selling electricity, and operated under their power purchase agreements, or PPAs. In other words, the plants were placed in service in 2008.
The case clarifies the meaning of the terms of art "assigned function" and "critical testing" with respect to the placed-in-service doctrine as applied to power generation projects.
Read the full Law360 article, "Ampersand clarifies power project placed-in-service analysis."
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The UK Football Governance Bill (the Bill), reintroduced by the current Labour government in 2024, marks a significant shift in the regulation of English football.
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The Ontario Securities Commission (OSC) is seeking public comment until September 3, 2025, on a proposal (the Proposal) to prohibit persons and companies from participating in prospectus offerings and private placements made by reporting issuers in Ontario when such persons or companies recently sold short the equity security being offered.
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Most incidents handled by our Norton Rose Fulbright cyber team originate from the customer’s service provider. In many cases it is the service provider’s systems, infrastructure and environment which proves to be the most vulnerable to cyber breaches and security issues.
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