There is a possibility for one or more additional reconciliation bills during late 2025 and 2026 and therefore opportunities for enactment of additional provisions, as well as changes and improvements to the Legislation....more
8/12/2025
/ Bonus Depreciation ,
Budget Reconciliation ,
Business Income ,
New Legislation ,
Qualified Opportunity Funds ,
Qualified Small Business Stock ,
Startups ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Legislation ,
Tax Planning ,
Venture Capital
There is a possibility of one or more additional reconciliation bills during late 2025 and 2026 and therefore further opportunities for enactment of additional provisions, as well as changes and improvements to the...more
8/6/2025
/ Budget Reconciliation ,
Energy Policy ,
Energy Sector ,
Executive Orders ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
New Legislation ,
Renewable Energy ,
Tax Credits ,
Tax Legislation ,
Trump Administration
The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more
7/21/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Budget Reconciliation ,
Congressional Committees ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EU ,
G7 ,
GILTI tax ,
International Tax Issues ,
IRS ,
Multinationals ,
OECD ,
Public Policy ,
Tax Cuts and Jobs Act ,
Tax Legislation ,
Tax Reform ,
US Trade Policies
The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more
7/14/2025
/ Corporate Counsel ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Legislative Agendas ,
Pass-Through Entities ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Taxation
The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more
7/8/2025
/ Corporate Taxes ,
Employee Benefits ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Mortgage REITS ,
Opportunity Zones ,
Popular ,
Qualified Small Business Stock ,
Research and Development ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Legislation ,
Tax Reform ,
Trump Administration
The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions has begun, with House Ways & Means Committee proposals (the Markup) to spend...more
5/15/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Employee Benefits ,
Executive Compensation ,
Federal Budget ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Proposed Legislation ,
Renewable Energy ,
SALT ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Legislation ,
Tax Reform
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more
The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more
The IRS and Treasury on June 3 issued proposed regulations under Sections 45Y and 48E (proposed regulations), which address clean electricity production and investment tax credits, respectively, that generally replace...more
On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more
3/13/2024
/ Energy Projects ,
Grants ,
IRS ,
Loans ,
New Regulations ,
Partnerships ,
Production Tax Credit ,
Registration Requirement ,
Renewable Energy ,
S-Corporation ,
Tax Credits ,
Tax Exempt Entities ,
Tax Returns ,
U.S. Treasury
As covered in our prior alerts, the Inflation Reduction Act enacted new renewable energy credits, including an advanced manufacturing production credit under Section 45X that provides tax credits to domestic producers and...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
9/18/2023
/ Apprenticeships ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Penalties ,
Prevailing Wages ,
Production Tax Credit ,
Recordkeeping Requirements ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act[1] (IRA) modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable...more
As covered in our prior alert, the Inflation Reduction Act[2] (IRA) modified and reinstated existing renewable energy credits and enacted new renewable energy credits. The IRA also enacted two novel alternatives to tax equity...more
On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more
Key Takeaways:
..Recently enacted direct pay and transfer provisions apply to certain clean energy tax credits. These provisions will have a significant impact on how taxpayers can monetize these tax credits and, in...more
9/16/2022
/ Biden Administration ,
Carbon Capture and Sequestration ,
Clean Energy ,
Climate Change ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
Monetization ,
Production Tax Credit ,
Renewable Energy ,
Tax Credits
Key Takeaways:
..The Senate voted 51-50 on August 7 to pass the Inflation Reduction Act.
..The legislation is expected to pass the House this week without changes and to be signed by President Biden.
..The...more
8/8/2022
/ Climate Change ,
Corporate Taxes ,
Drug Pricing ,
Energy Projects ,
Federal Funding ,
Inflation Adjustments ,
Medicare ,
Oil & Gas ,
Pending Legislation ,
Prescription Drugs ,
Renewable Energy ,
Superfund ,
Tax Credits
Key Takeaways:
..The law regarding computation of FBAR penalties is unclear.
..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts.
..Until the Supreme Court...more
The House Ways and Means Committee this week released draft legislation advancing various tax change proposals. The House action follows several recent releases by the Senate Finance Committee, including proposals focused on...more
The White House and Treasury today released the Fiscal Year 2022 Federal Budget and the Treasury Green Book, which include new details regarding the Biden administration’s American Families Plan and proposed 2021 tax changes...more
The White House today released The American Families Plan, which includes some new details regarding the Biden administration’s proposed 2021 tax reform. The tax changes expected to be enacted this year will be substantial...more