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'One Big Beautiful Bill Act' Tax Provisions: A First-Take Comparison of the House and the Final Senate Versions

The tax proposal originally offered by the US House of Representatives and the final version of the comprehensive budget reconciliation bill, the One Big Beautiful Bill Act, as developed in the Senate, contain some key...more

One Big Beautiful Bill Act Tax Proposals: Select Highlights and Implications

The US House of Representatives on May 22, 2025 passed the One Big Beautiful Bill Act (the Act), which includes a tax package that would extend certain provisions of the 2017 Tax Cuts and Jobs Act set to expire at the end of...more

Renewables Under the New Administration: Navigating an Uncertain Roadmap

Recent policy shifts at the federal level have introduced significant variability to the US renewable energy sector. While demand for clean energy continues to grow, executive orders, regulatory changes, and evolving...more

The State of Play for Energy Storage Tax Credits

The energy storage industry has continued to progress over the course of 2024 and into 2025, buoyed in significant part by the federal income tax benefits in the form of tax credits enacted under the Inflation Reduction Act...more

Elective Safe Harbor Released for IRA Domestic Content Tax Credit ‘Adder’

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 ‘Three Pillars’ of EAC Use and the Proposed Regulations for Clean Hydrogen Tax Credit

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

IRS Guidance and Impact on the Energy Storage Industry

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

Treasury and IRS Publish Much-Anticipated Guidance on Clean Hydrogen Tax Credit

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

IRA’s Advanced Manufacturing Production Credit: IRS Publishes Proposed 45x Regulations

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

Treasury and IRS Publish Long-Awaited Guidance on Renewable Energy Investment Tax Credit

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

IRS and Treasury Release Credit Transfer Guidance Aiming to Jump Start Market for Ira's Clean Tech Industry Tax Credit Sales

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

IRS Releases Highly Anticipated Guidance on Domestic Content IRA Tax Credit ‘Adder’

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

IRA's Energy Community Tax Credit ‘Adder’: IRS Releases Taxpayer-Favorable Guidance

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

IRS and DOE Publish Details on First Allocation of $10B Section 48C Green Technology Industry Tax Credits Authorized by IRA

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 Trends—and Traps—that Will Shape 2023

The last few years have thrown many surprises at businesses. Organizations across all sectors have faced inflation, global conflicts, supply chain challenges, a pandemic, and continually changing government policies. In 2023,...more

New Year Brings New Opportunities for Energy Storage (and Utilities)

On January 1, 2023, newly constructed standalone energy storage facilities became eligible for an investment tax credit (ITC) under Section 48 of the Internal Code of 1986, as amended (Code), pursuant to provisions of the...more

IRS Publishes Critical Prevailing Wage and Apprenticeship Requirement Guidance for IRA Tax Credits

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

Inflation Reduction Act Would Significantly Expand Federal Income Tax Benefits for Green Technology Industry

The Inflation Reduction Act of 2022 proposes significant changes and expansions to the existing federal income tax benefits for renewable energy, fuel production, and other green technologies....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

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

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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