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Are Investment Tax Credit Changes in Store for Energy Storage?

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

Largely Taxpayer-Friendly Final Regulations Released Under Section 45Q Carbon Capture Credit

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

New COVID-19 Relief Legislation Extends Renewable Energy and Green Technology Industry Tax Incentives

A new coronavirus (COVID-19) relief bill—the Consolidated Appropriations Act, 2021, which includes the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (the Act)—was signed into law on December 27. The Act not only...more

Congress Updates US Energy Policy, Incorporates Energy-Related Tax Provisions Through Consolidated Appropriations Act, 2021

The US Congress has adopted the first extensive update to US federal energy policies in over a decade in the Energy Act of 2020 (Energy Act), which President Donald Trump signed into law on December 27 as part of the...more

New Proposed Regulations Provide Clarity for Claiming Carbon Capture and Sequestration Tax Credits

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

IRS Releases Proposed Regulations for Carbon Sequestration Tax Credit

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

Beware of Debtor Tax Traps in Restructuring and Bankruptcy

The economic outcome from the coronavirus (COVID-19) pandemic is still uncertain but is likely to remain catastrophic in many respects. Of late popular name brands and companies have filed for bankruptcy as stay-at-home...more

IRS Provides Guidance on Elections Related to Section 163(j) Business Interest Limitation

Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more

IRS Releases Tax Return Amendment Relief for BBA Partnerships

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

IRS, Treasury Issue Guidance on ‘Business Interest Expense’ Limitation

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

IRS, Treasury Issue Guidance on Section 965 Deemed Repatriation Rules, Signal Important Form 5471 Exception

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

Hurricane Irma Client Alert: Tax Filing, Payment Deadlines Extended for Victims in Disaster Areas

Victims of Hurricane Irma located in areas designated by the Federal Emergency Management Agency as qualifying for individual assistance now have until January 31, 2018 to file certain federal tax returns and make certain...more

Hurricane Harvey Client Alert: Tax Filing and Payment Deadlines Extended for Victims

Victims of Hurricane Harvey in some designated areas now have until January 31, 2018 to file certain federal tax returns and make payments....more

Impact of New Tax Regulations on Intercompany Debt Obligations

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

New Legislation Extends and Modifies Renewable Energy Industry Tax Incentives

The five-year tax credit extension for wind and solar power facilities is a welcome development for the renewable energy industry in light of recent indications by Congress of a push to end tax credit benefits for wind and...more

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