This page of the tax equity analysis addresses issues associated with the tax code that may limit the amount of the tax benefits.  I discuss issues like the DRO (deficit restoration obligation), the outside capital account, suspended losses, 734 depreciation adjustments, qualified income offset, hypothetical liquidation at book value, 704(b) inside capital account, minimum gain … Continue reading Tax Equity Structures in U.S. – DRO’s, Stop Loss, Outside Capital Account …