Gregory Hartker

Morgan Lewis

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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

6/16/2025 / Clean Energy , Energy Policy , Energy Sector , Inflation Reduction Act (IRA) , Investment Funds , Proposed Legislation , Renewable Energy , Tax Credits , Tax Planning , Tax Reform

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

1/17/2025 / Corporate Taxes , Income Taxes , Internal Revenue Code (IRC) , IRS , OECD , Tax Liability , Tax Planning , U.S. Treasury

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

6/26/2023 / Energy Projects , Energy Sector , Inflation Reduction Act (IRA) , Investment Tax Credits , IRS , Production Tax Credit , Tax Credits , U.S. Treasury

The GILTI Rules – A Comprehensive Q&A on the New Proposed Regulations

The US Department of the Treasury and the Internal Revenue Service provided guidance on the Global Intangible Low Taxed Income rules, answering some, but by no means all, of the questions raised by taxpayers and practitioners...more

9/21/2018 / GILTI tax , IRS , Tax Cuts and Jobs Act , Tax Reform , U.S. Treasury

M&A and Tax Reform—New Tax Considerations with Wide-Ranging Implications

New tax provisions have significant impact on structuring mergers and acquisitions. In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more

1/6/2018 / Acquisitions , Mergers , Net Operating Losses , Tax Reform , Withholding Tax

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