On August 15, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued much-anticipated guidance (Notice 2025-42) regarding the determination of when an applicable wind or solar facility is...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On July 1, 2025, the Senate passed One Big Beautiful Bill (OBBB) in a 51-50 vote, with Vice President J.D. Vance casting a tiebreaker vote. Although the House of Representatives previously passed its own version of OBBB (see...more
7/7/2025
/ China ,
Clean Energy ,
Energy Policy ,
Energy Projects ,
Federal Budget ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
New Legislation ,
Popular ,
Renewable Energy ,
Tax Credits ,
Trump Administration
On June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
6/12/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Cryptoassets ,
Financial Institutions ,
Financial Services Industry ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
IRS ,
OECD ,
Reporting Requirements ,
Tax Credits ,
Tax Cuts and Jobs Act
The House of Representatives narrowly passed the One Big Beautiful Bill along party lines. The proposed bill would terminate or otherwise make significant changes to several of the energy tax credits created or expanded by...more
[unable to retrieve full-text content]On April 25, 2024, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations on the transferability of certain tax credits under the...more
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more