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New Guidance on the Commercial EV Tax Credit

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

U.S. Tax Court Invokes Loper Bright for the First Time

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

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

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

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