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Tax Court: As to Listed Transaction, IRS Must Adhere to APA

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Better Late Than Never: IRS Proposes an End to Expansive Section 263A Associated Property Rule

More than a decade after the associated property rule was invalidated by the U.S. Court of Appeals for the Federal Circuit in Dominion Resources, Inc. v. United States, 681 F.3d 1313 (Fed. Cir. 2012), the U.S. Department of...more

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Guidance, Model Provide Additional Clarity for 40B Sustainable Aviation Fuel Tax Credit

The U.S. Department of the Treasury and IRS released Notice 2024-37 on April 30, 2024, regarding the Sustainable Aviation Fuel (SAF) Tax Credit found at Section 40B of the Internal Revenue Code as an income tax credit and...more

IRS: Use of "Attrition Allowance" to Calculate Rate Base Violates Normalization Consistency Rules

Consistent with a state commission's existing regulatory policy, a utility's rate base for the first two years of the three-year rate cycle was computed using traditional cost-of-service/rate of return principles....more

Treasury Department, IRS Issue Additional Section 45V Clean Hydrogen PTC Guidance

The U.S. Department of the Treasury Department and IRS on April 10, 2024, issued a supplemental notice of proposed rulemaking (NPRM) under the Internal Revenue Code's Section 45V clean hydrogen production tax credit (PTC)....more

Inflation Reduction Act Direct Pay Rules Finalized

The U.S. Department of the Treasury and IRS released final regulations under Section 6417 of the Internal Revenue Code, as enacted by the Inflation Reduction Act (IRA). Section 6417 allows certain taxpayers to elect to...more

Treasury Department and IRS Release Final Regulations on the Direct Payment of Tax Credits

The U.S. Department of the Treasury and IRS on March 5, 2024, released final regulations regarding the direct payment of tax credits under Section 6417 of the Internal Revenue Code (Elective Payment of Applicable Credits)....more

IRS Updates and Modernizes Rules Governing Utility Securitizations

Since the issuance of Revenue Procedure (Rev. Proc.) 2005-62, many utilities have used securitizations authorized by state law to secure collections of stranded costs upon the retirement of certain generation plants or costs...more

Treasury Department, IRS Correct Section 48 Proposed Regulations on Qualified Biogas Property

The U.S. Department of the Treasury and IRS on Feb. 16, 2024, released a correction to Internal Revenue Code Section 48 Proposed Regulations relating to the new investment tax credit (ITC) for biogas. The correction provides...more

Inflation Reduction Act Direct Pay and Transfer Pre-Filing Registration Is Open for Business

The IRS launched its Inflation Reduction Act (IRA) Pre-Filing Registration Tool in late 2023 for elective (direct) payments under Section 6417 and tax credit transfers under Section 6418 of the Internal Revenue Code....more

Treasury, IRS Release Section 30C Alternative Fuel Vehicle Refueling Property Credit Guidance

The U.S. Department of the Treasury and IRS on Jan. 19, 2024, released Notice 2024-20, stating their intent to issue proposed regulations regarding the Alternative Fuel Vehicle Refueling Property Credit under Section 30C of...more

Eyes on Energy Tax Update: Fourth Quarter 2023

Eyes on Energy Tax Update is a quarterly publication of the Holland & Knight Renewable and Alternative Energy Tax Team that provides highlights of important developments. The Renewable and Alternative Energy Tax Team also...more

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

Treasury, IRS Release Section 45V Clean Hydrogen PTC Proposed Regulations

The U.S. Department of the Treasury and IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

An In-Depth Look at Section 45X Proposed Regulations

The U.S. Department of the Treasury and IRS on Dec. 14, 2023, released Proposed Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. (See Holland& Knight's previous...more

IRS, Treasury Department Release New Section 40B Sustainable Aviation Fuel Credit Guidance

The IRS and U.S. Department of the Treasury released on Dec. 15, 2023, Notice 2024-06 regarding Section 40B of the Internal Revenue Code. Effective for fuel mixtures sold or used after Dec. 31, 2022, and before Jan. 1, 2025,...more

Breaking Down the Section 48 Investment Tax Credit Proposed Regulations

The U.S. Department of the Treasury and IRS on Nov. 17, 2023, released long-awaited proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code. Section...more

Section 48 Proposed Regulations Detail Treatment of Qualified Biogas Property

The U.S. Department of the Treasury on Nov. 17, 2023, issued proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code (Code) that, following passage...more

Public Utility Commission Rules Taxpayer Entitled to Collect Tax Expense, Notwithstanding NOLs

A Missouri regulated public utility had net operating losses (NOLs) not attributable to accelerated depreciation, so the normalization rules did not apply. The Missouri Public Service Commission (MPSC) confirmed that tax...more

Condemned to Lose Your ADIT?

In a private letter ruling, the IRS concluded that the condemnation of public utility property is in effect a "retirement" or "disposition" that requires the elimination of accumulated deferred income taxes (ADIT) associated...more

Highlights of the Proposed Regulations on IRA Prevailing Wage and Apprenticeship Requirements

The U.S. Department of the Treasury and IRS on Aug. 29, 2023, announced proposed regulations regarding increased credit or deduction amounts for which taxpayers can qualify by meeting prevailing wage and registered...more

Eyes on Energy Tax Update: Second Quarter 2023

The second quarter of 2023 saw continued developments as a result of the enactment of the Inflation Reduction Act of 2022 (IRA), court activity and announcements from federal agencies. Below, we summarize the updates you need...more

Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more

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