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“One Big Beautiful Bill Act” signed into law: Clean energy credits and new FEOC/ Prohibited Foreign entity rules

On July 4, 2025, President Trump signed into law the One, Big, Beautiful Bill Act. The Act includes significant amendments to tax credits originally enacted and/or amended under the Inflation Reduction Act of 2022 (“IRA”)...more

Implications of new FEOC restrictions on clean energy tax credits

On May 12, 2025, the House Ways and Means Committee reported out a significant tax reconciliation bill, known as the “One, Big, Beautiful Bill.” While the bill aims to extend and enhance several provisions from the 2017 Tax...more

Full U.S. House passes “One Big Beautiful Bill” – Impact on energy

On May 22, 2025 the House of Representatives, by a vote of 215-214 (no Democrats supporting), passed the One Big, Beautiful Bill Act (“OBBB”) which includes manager’s amendment changes from the version passed by the Ways and...more

House advances 'One Big Beautiful Bill': Implications of new FEOC restrictions on clean energy tax credits

On May 12, 2025, the House Ways and Means Committee reported out a significant tax reconciliation bill, known as the “One, Big, Beautiful Bill.” While the bill aims to extend and enhance several provisions from the 2017 Tax...more

House passes “One Big, Beautiful Bill”– Impact on energy

On May 13, 2025 the House passed the “One Big, Big, Beautiful Bill,” which includes significant cuts to the Inflation Reduction Act (IRA) energy incentives. The changes shorten the duration of or eliminate 17 IRA “green”...more

Shaking up the Magic 8-Ball – What does the U.S. IRA Monetization Look Like in 2025?

First, a quick and brief reminder on the IRA and the monetization techniques. The IRA expanded upon existing energy tax credits (and other tax incentives) and introduced new ones. And critically, the IRA also brought to life...more

What will happen to IRA clean energy subsidies in the Trump Administration?

The Inflation Reduction Act of 2022 (IRA) was one of the most significant legislative victories of the Biden administration, fostering tens of billions (USD) in planned clean energy investments, much of this yet to be...more

U.S. Departments of Energy and the Treasury issue final EV credit rules under the IRA

Newly issued final EV tax credit rules largely stick to proposed rules with some flexibility on graphite through end of ’26, clarifications on FEOC definitions that could be significant. On May 3, 2024 the Department of the...more

Biden administration issues long-awaited EV tax credit FEOC guidance

On Friday, December 1, 2023, the U.S. Department of Energy (DOE) and U.S. Department of Treasury concurrently released long-anticipated proposals regarding the “Foreign Entity of Concern” (FEOC) exclusion—a key provision...more

Carbon Capture, Delays at EPA and 45Q tax credits post-Inflation Reduction Act

Nearly 15 years out from the original enactment of the 45Q tax credit, and a year after the significant expansion of the credit included in the Inflation Reduction Act (“IRA”), we are seeing the expanded 45Q finally starting...more

Land of opportunity – why Australian investors are being drawn to the United States

Billions of dollars worldwide are pouring into the transition to green energy, no more so than in the United States (U.S.) where new legislation is providing a powerful stimulus. For Australian investors, the opportunity to...more

Treasury issues proposed regulations on IRA elective pay and transferability of tax credits

On Wednesday, June 14, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations (the “Proposed Regulations”) on the Inflation Reduction Act’s (IRA) two new credit delivery mechanisms for...more

DOE and Treasury issue further guidance on investment tax credits for advanced energy projects (48C)

The Inflation Reduction Act of 2022 extended the 48C tax credit program, initially enacted in the American Recovery and Reinvestment Act of 2009, and provided an additional $10 billion in credit allocations. In this unusual...more

美国政府对“受关注外国实体”作出定义,影响波及《降低通胀法》项下电动汽车电池

2023年3月21日(星期二),美国商务部发布一则关于《芯片与科学法》所含护栏条款的拟议规则通知。作为拟议规则的组成部分,美国商务部发布了“受关注外国实体”和由受关注国家“拥有、控制、管辖或指挥”的定义,这两个术语曾出现在过去两年颁发的四部独立制定法中,即:《2021财年国防授权法》、《基础设施投资和就业法》、《芯片与科学法》和《降低通胀法》。根据美国商务部所拟定义,任何实体——包括总部位于美国的实体或注册在美国的实体——如其25%及以上表决权益...more

Administration defines “Foreign Entity of Concern” with implications for EV batteries under the IRA

On Tuesday, March 21, 2023, the US Department of Commerce issued a notice of proposed rulemaking on the guardrail provisions included in the CHIPS and Science Act (CHIPS). As part of the proposed rule Commerce issued a...more

New rules for electric vehicles tax credits raise concerns under U.S. international obligations

The Inflation Reduction Act (IRA) was signed into law by President Biden on August 16, 2022. The IRA made major changes to United States rules for electric vehicle (EV) tax credits. The IRA and its implications for...more

The IRA’s electric vehicle and battery credits: More complexity and more benefit for US manufacturing

The Inflation Reduction Act (IRA) includes a significant expansion of U.S. electric vehicle (EV) tax credits.  In contrast to the IRA’s extensions of other preexisting clean energy tax incentives, the IRA’s consumer EV tax...more

The IRA: Incentives for development and use of clean fuels in transportation

Among the goals of the newly enacted Inflation Reduction Act (IRA) is to encourage the decarbonization of mobile sources, including vehicle, aviation, marine, and heavy duty transport. To that end, the IRA establishes many...more

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