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The One Big Beautiful Bill Act: Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more

Tax Credit Implications of the One Big Beautiful Bill Act

On May 22, the U.S. House of Representatives passed an amended version of H.R. 1—the One Big Beautiful Bill Act (the Bill) — by a vote of 215-214. The House-passed version of the bill, slated to be considered by the Senate...more

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

The One Big Beautiful Bill: Initial Analysis of Key Provisions for the Real Estate Industry

On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

Treasury and IRS Issue Updated Domestic Content Guidance Under IRA and First Updated Elective Safe Harbor

On January 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-08 (Notice), which provides an updated safe harbor (First Updated Elective Safe Harbor) that modifies and otherwise...more

Treasury and IRS Issue Final Regulations on Clean Electricity Production and Investment Tax Credits

On January 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published final regulations providing further guidance on the clean electricity production credit under Section 45Y and the clean...more

IRS Issues Final Regulations on Clean Hydrogen Tax Credits

The IRS and the Treasury Department issued final regulations on January 3 (Final Regulations), providing guidance on the clean hydrogen production tax credit under Section 45V (Hydrogen PTC) and the investment tax credit...more

IRS Releases Final Direct Pay Energy Tax Credit Regulations

On March 5, 2024, the Internal Revenue Service and the Treasury Department issued final Treasury Regulations (the “Final Regulations”) updating and finalizing previously published proposed Treasury Regulations relating to the...more

IRS Issues Carried Interest Guidance

On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more

BIG Haircut –Treasury Department Proposes to limit the use of NOLs on Certain Corporate Mergers and Acquisitions via 382 Built-in...

On September 9, 2019, the U.S. Department of the Treasury issued proposed regulations that would limit the ability of certain corporations to utilize prior year losses, potentially increasing the tax burden of such...more

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