On August 15, 2025, the IRS released new beginning of construction (BOC) guidance for solar and wind facilities claiming production and investment tax credits under sections 45Y and 48E of the Internal Revenue Code in IRS...more
President Trump signed the “One, Big, Beautiful Bill Act” (the “OBBB”) into law on July 4, 2025. Congress passed the legislation using the budget reconciliation process to avoid the 60-vote Senate filibuster. In addition to...more
On May 22, 2025, the U.S. House of Representatives passed a highly anticipated piece of legislation - commonly referred to as “The One, Big, Beautiful Bill” (the “Bill”) - by a mostly party-line vote of 215-214-1 (two...more
5/22/2025
/ Clean Energy ,
Energy Policy ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
New Legislation ,
Popular ,
Production Tax Credit ,
Renewable Energy ,
Tax Credits ,
Tax Reform
On May 29, 2024, the Internal Revenue Service (IRS) and the Department of Treasury issued proposed regulations (REG-119283-23) addressing the new technology neutral clean electricity production tax credit (PTC) in section 45Y...more
On May 16, 2024, the Internal Revenue Service (IRS) issued further guidance (Notice 2024-41, the Additional Notice) intended to provide clarity and certainty surrounding the domestic content1 bonus credit by (among other...more
Guidance recently issued by the Department of the Treasury and the Internal Revenue Service (IRS) in proposed regulations (REG-117631-23) will (if held to be final) have a significant impact on green hydrogen projects in the...more
1/18/2024
/ Clean Energy ,
Comment Period ,
Energy Tax Incentives ,
Energy-Efficiency Tax Credits ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Internal Revenue Code (IRC) ,
IRS ,
Production Tax Credit ,
Proposed Guidance ,
Proposed Regulation ,
Regulatory Agenda ,
Renewable Energy ,
U.S. Treasury
On June 14, 2023, the Internal Revenue Service and the Treasury Department issued (among other guidance) an expansive set of proposed regulations explaining how taxpayers can monetize 11 green energy tax credits through...more
On May 31, the Treasury Department issued proposed regulations (REG-110412-23) detailing how small solar and wind facilities located in or connected to low-income communities (LIC) can qualify for the so-called Low-Income...more
A reasonable analysis of the Buy America standards for manufactured products would have resulted in the qualified facility or energy project being treated as the end product. One would then check to see if the components of...more
The Autonomous Systems & Advanced Mobility (ASAM) space is headed for more change in 2023, generating new opportunities and challenges for a growing list of industry players. The adoption of new, complex and connected...more
5/9/2023
/ Aerospace ,
Artificial Intelligence ,
Automation Systems ,
Aviation Industry ,
Cybersecurity ,
Electric Vehicles ,
Emerging Technologies ,
Environmental Social & Governance (ESG) ,
FCC ,
Federal Aviation Administration (FAA) ,
Innovative Technology ,
Intellectual Property Protection ,
Transportation Industry
The Internal Revenue Service (IRS) released its initial guidance (the Advanced Energy Project (AEP) Notice, Notice 2023-18) establishing procedures for taking advantage of the renewed and expanded qualifying advanced energy...more
While the Internal Revenue Service (IRS) may have nominally satisfied the 180-day deadline in the Inflation Reduction Act (IRA) to establish procedures for taking advantage of special rules applicable to small solar and wind...more
Today, President Biden signed the Inflation Reduction Act of 2022 (IRA) into law. The final IRA bill came together after more than 18 months of intra-party negotiations among Democrats about what legislative priorities to...more
The following alert provides a high level update to the August 4 Akin Gump comprehensive section-by-section report, which was published before the Senate vote-a-rama and final Senate passage. This update is being published...more
The Coronavirus Aid, Relief and Economic Security Act (CARES Act) (P.L. 116-136), signed into law March 27, contained numerous business relief provisions, one of which was a repeat from the 2008-2009 financial crisis. While...more
On March 25, 2020, the U.S. Senate released final text of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (H.R. 748) to provide emergency economic assistance to those affected by the novel coronavirus...more
3/30/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
Federal Taxes ,
Financial Stimulus ,
Income Taxes ,
IRS ,
Net Operating Losses ,
Payroll Taxes ,
Tax Code ,
Tax Credits ,
Tax Deductions ,
Tax Relief
• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...more
5/24/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Debt Financing ,
Intangible Property ,
Investment Funds ,
Opportunity Zones ,
Original Use ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Safe Harbors ,
Tangible Property
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
10/25/2018
/ Asset Management ,
Capital Assets ,
Capital Gains ,
Community Development ,
Economic Development ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low-Income Issues ,
New Rules ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Public Finance ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Rollover Equity ,
Safe Harbors ,
State and Local Government ,
Tax Benefits ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Exemptions ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury ,
Value Appreciation
• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital.
• States, cities,...more
9/19/2018
/ Community Development ,
Draft Guidance ,
Economic Development ,
Fund Managers ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Real Estate Development ,
State and Local Government ,
Strategic Planning ,
Tax Benefits ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
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