The Internal Revenue Service ("IRS") has issued Notice 2025-42 to implement the One Big Beautiful Bill Act ("OBBBA") mandate to phase out the clean electricity production tax credit (§ 45Y) and investment tax credit (§ 48E)...more
8/19/2025
/ Clean Energy ,
Construction Project ,
Energy Projects ,
Federal Budget ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
New Guidance ,
One Big Beautiful Bill Act ,
Production Tax Credit ,
Regulatory Reform ,
Renewable Energy ,
Solar Energy ,
Tax Credits ,
Trump Administration ,
Wind Power
The One Big Beautiful Bill Act (the “OBBBA”), which was passed on July 4, 2025, included several changes to the energy tax credits introduced and expanded by the Inflation Reduction Act of 2022 (the “IRA”). The key changes to...more
8/4/2025
/ Clean Energy ,
Climate Change ,
Electric Vehicles ,
Energy Policy ,
Energy Tax Incentives ,
Environmental Policies ,
Federal Budget ,
Foreign Entities ,
Greenhouse Gas Emissions ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
New Legislation ,
One Big Beautiful Bill Act ,
Renewable Energy ,
Tax Credits ,
Tax Policy ,
Tax Reform ,
Trump Administration
The One Big Beautiful Bill Act expands the qualified small business stock benefits available to founders and investors....more
7/18/2025
/ Federal Budget ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
New Legislation ,
One Big Beautiful Bill Act ,
Qualified Small Business Stock ,
Small Business ,
Tax Benefits ,
Tax Cuts ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
Trump Administration
The One Big Beautiful Bill Act modifies the requirements for clean energy tax credits....more
7/10/2025
/ Clean Energy ,
Energy Policy ,
Energy Projects ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
Investment ,
New Legislation ,
One Big Beautiful Bill Act ,
Regulatory Requirements ,
Renewable Energy ,
Tax Credits ,
Tax Reform ,
Trump Administration
In this new trade landscape, it is more important than ever to coordinate customs and operational planning with income taxes and transfer pricing....more
5/22/2025
/ Customs ,
First Sale Doctrine ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Imports ,
Income Taxes ,
Inventory ,
Retail Market ,
Risk Management ,
Suppliers ,
Supply Chain ,
Tariffs ,
Tax Liability ,
Tax Planning ,
Transfer Pricing ,
Trump Administration
The One, Big, Beautiful Bill would significantly limit tax credits for clean energy and manufacturing introduced or expanded under the Inflation Reduction Act of 2022....more
5/16/2025
/ China ,
Clean Energy ,
Energy Policy ,
Energy Projects ,
Foreign Entities ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Investment ,
Investment Tax Credits ,
Production Tax Credit ,
Proposed Legislation ,
Renewable Energy ,
Russia ,
Tax Credits
In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...more
1/27/2025
/ Automotive Industry ,
Biden Administration ,
Clean Energy ,
Electric Vehicles ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Motor Vehicles ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more
1/24/2025
/ Corporate Taxes ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
NPRM ,
Proposed Regulation ,
Reporting Requirements ,
Spinoffs ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Tax-Free Spin-Offs
The Department of Treasury and the IRS have released Notices 2025-10 and 2025-11, outlining intended forthcoming proposed regulations for the Section 45Z clean fuel production credit introduced by the Inflation Reduction Act...more
1/23/2025
/ Biodiesel ,
Clean Energy ,
Clean Fuels Program (CFP) ,
Climate Change ,
Greenhouse Gas Emissions ,
Inflation Reduction Act (IRA) ,
IRS ,
Proposed Regulation ,
Regulatory Agenda ,
Renewable Energy ,
Renewable Fuel ,
Tax Credits ,
Tax Reform ,
U.S. Treasury
The Department of Treasury and the Internal Revenue Service released final regulations regarding the Section 45Y clean electricity production and Section 48E clean electricity investment tax credits....more
The Department of Treasury and the Internal Revenue Service issued final regulations regarding the Section 45V clean hydrogen production credit....more
The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations for the investment tax credit under section 48, providing guidance for projects that start construction by December 31, 2024....more
The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more
12/3/2024
/ Clean Energy ,
Energy Policy ,
Energy Projects ,
Energy Tax Incentives ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Oil & Gas ,
Renewable Energy ,
Tax Credits ,
Tax Exempt Entities ,
U.S. Treasury
The Department of Treasury and the Internal Revenue Service ("IRS") issued final regulations regarding the advanced manufacturing production tax credit....more
The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more
8/30/2024
/ Chevron Deference ,
Corporate Counsel ,
Foreign Subsidiaries ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
SCOTUS ,
Tax Court ,
Tax Liability ,
U.S. Treasury
The Background: The U.S. Treasury Department ("Treasury") issued regulations finalizing the reporting requirements on the 1% corporate stock buyback tax and starting the clock on the tax's first filing and payment deadline....more
The Background: The Inflation Reduction Act ("IRA") created or enhanced various tax credits for qualifying renewable energy projects. However, a taxpayer loses 80% of otherwise-available IRA credits unless prevailing wage...more
7/5/2024
/ Apprenticeships ,
Clean Energy ,
Department of Labor (DOL) ,
Employer Liability Issues ,
Energy Projects ,
Inflation Reduction Act (IRA) ,
IRS ,
Prevailing Wages ,
Renewable Energy ,
Tax Credits ,
Wage and Hour
The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more
6/3/2024
/ Clean Energy ,
Energy Projects ,
Greenhouse Gas Emissions ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Oil & Gas ,
Production Tax Credit ,
Proposed Regulation ,
U.S. Treasury ,
Zero Emission Credits
The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more
5/15/2024
/ Automotive Industry ,
Clean Car Standards ,
Clean Energy ,
Department of Energy (DOE) ,
Due Diligence ,
Electric Vehicles ,
Federal Taxes ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
IRS ,
Proposed Guidance ,
Supply Chain ,
Tax Credits ,
U.S. Treasury
The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more
On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more
5/6/2024
/ Cross-Border ,
Cross-Border Transactions ,
Excise Tax ,
Internal Revenue Code (IRC) ,
IRS ,
Merger Agreements ,
New Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Share Buybacks ,
U.S. Treasury
The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more
New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...more
1/3/2024
/ Automotive Industry ,
Clean Car Standards ,
Clean Energy ,
Department of Energy (DOE) ,
Electric Vehicles ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
IRS ,
Motor Vehicles ,
Proposed Guidance ,
Tax Credits ,
U.S. Treasury
Proposed regulations addressing new tax reporting requirements for cryptocurrencies and other digital assets have been issued by the IRS and Treasury....more
A new program offers rulings in 12 weeks, even absent a showing of business need.
Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more
8/3/2023
/ Annual Filings ,
Corporate Taxes ,
Fast Track Process ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Revenue Procedures ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Time Extensions ,
U.S. Treasury