The US Department of Treasury and the IRS on May 16 released Notice 2024-41, which provides a new elective safe harbor that taxpayers may use to qualify for the domestic content bonus credit amount under Sections 45, 45Y, 48,...more
The Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) published proposed regulations (the Proposed Regulations) in late December 2023 setting forth rules that would apply to the tax credits for...more
The Inflation Reduction Act of 2022 (IRA) enacted a wide range of legislation intended to further a variety of policy goals, including decarbonization, energy and resource security, environmental justice, and good-paying job...more
The Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) recently published proposed regulations (Proposed Regulations) setting forth rules applicable to the credit for the production of clean...more
1/8/2024
/ Energy Projects ,
Energy Sector ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
The Internal Revenue Service’s proposed Section 45X regulations, released on December 15, provide US-based manufacturers with much-anticipated guidance for a credit that has been available since the beginning of 2023....more
The US Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released proposed regulations on November 17, 2023 addressing the investment tax credit (ITC) for renewable energy and energy storage...more
On June 14, 2023, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released temporary regulations (Temporary Regulations) and proposed regulations (Proposed Regulations; collectively with the...more
The Internal Revenue Service and US Department of the Treasury released Notice 2023-38 on May 12, which establishes rules for testing an applicable “green” energy facility’s eligibility for a bonus federal income tax credit...more
The highly anticipated guidance for determining a “green” energy facility’s eligibility for the potentially valuable tax credit increase largely aligns with industry expectations, including by providing certainty on energy...more
he Internal Revenue Service (IRS), the Treasury Department (Treasury), and the Department of Energy (DOE) released Notice 2023-18 (Notice) on February 13, detailing the procedures through which the IRS and DOE will award a...more
The Internal Revenue Service (IRS) published Notice 2022-61 (the Notice) in the November 30 Federal Register to provide guidance on the key prevailing wage and apprenticeship labor standards (W&A Requirements) generally...more
The US energy storage industry is experiencing rapid growth, with approximately 3.5 gigawatt hours (GWh) of energy storage installed in 2020, which is greater than the aggregate 3.1 GWh of energy storage installed from 2013...more
The US Department of Treasury and the Internal Revenue Service released anticipated final regulations pertaining to the federal income tax credit for carbon capture projects under Section 45Q of the Internal Revenue Code on...more
1/12/2021
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Critical Infrastructure Sectors ,
Energy Projects ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Revenue Procedures ,
Tax Credits ,
Tax Planning ,
Urban Planning & Development
In our previous LawFlash, we summarized the key provisions of the proposed regulations pertaining to the technical mechanical and associated measurement, reporting, and certification requirements for the Section 45Q credit. ...more
The proposed regulations, released on May 28 and on which taxpayers may currently rely pending finalization, build on prior guidance for carbon capture and sequestration tax credits under Section 45Q of the Internal Revenue...more
6/2/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Critical Infrastructure Sectors ,
Energy Projects ,
Environmental Protection Agency (EPA) ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Real Estate Development ,
Renewable Energy ,
Revenue Procedures ,
Tax Credits ,
Tax Planning ,
Urban Planning & Development
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more
The Internal Revenue Service has released guidance allowing partnerships subject to amended return filing restrictions enacted under the Bipartisan Budget Act of 2015 to amend 2018 and 2019 partnership returns, including in...more
The guidance issued on February 19 by the Internal Revenue Service is the type that the carbon capture and storage industry had sought, and will hopefully open up the market for investment by eliminating tax-related...more
2/21/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Critical Infrastructure Sectors ,
Energy Projects ,
Greenhouse Gas Emissions ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Opportunities ,
Investment Tax Credits ,
Investors ,
IRS ,
Production Tax Credit ,
Qualifying Facility ,
Real Estate Development ,
Renewable Energy ,
Revenue Procedures ,
Safe Harbors ,
Tax Credits ,
Tax Equity Partnership ,
Tax Planning ,
Underground Storage Tanks ,
Urban Planning & Development
The US Department of the Treasury and the Internal Revenue Service on April 2 issued “Initial Guidance Under Section 163(j) as Applicable to Taxable Years Beginning After December 31, 2017” (Notice 2018-28), which announces...more
Notice 2018-13 details the government’s intent to issue regulations addressing additional Section 965 computational issues. The new regulations will clarify, among other things, that US shareholders will be permitted to elect...more
Victims of Hurricane Harvey in some designated areas now have until January 31, 2018 to file certain federal tax returns and make payments....more
The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more
11/3/2016
/ Collateralized Debt Obligations ,
Corporate Counsel ,
Foreign Corporations ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Multinationals ,
Parent Corporation ,
Private Equity ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
S-Corporation ,
Section 385 ,
Stocks