Ownership and depreciation
The letter focuses on whether the taxpayer or system owner has enough benefits and burdens of ownership to support depreciation treatment. That is a fact-specific legal and tax review, not a marketing conclusion.
Advisor review
Attorney letter
Olson & PartnersLaw opinion letterOlson & Partners Law opinion letter
This attorney opinion frames the legal questions around ownership, depreciation, federal solar tax credits, basis, passive activity treatment, and economic substance.
- Firm
- Olson & Partners Law
- Length
- 28 pages
- File
- 771 KB PDF
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Separate source-letter file for advisor review.
Federal solar tax credit
The letter addresses whether the solar energy property and transaction structure support review under the federal solar credit framework. A taxpayer's own advisor still has to test final documents, timing, basis, and limitations.
Basis and debt treatment
The letter discusses purchase price, basis, and recourse seller-note treatment as review items. This matters because basis drives depreciation and credit calculations.
Activity and substance
The letter flags active versus passive treatment, material participation, and economic-substance or sham-transaction considerations. Those issues depend on taxpayer facts and actual conduct.
Start your review
Treat the letter as a review input, not a final answer.
If the letter raises a possible fit question, start with a private intake and have your own CPA or tax attorney test the taxpayer facts before relying on anything.