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IRS Issues Beginning of Construction Guidance in Response to July Executive Order

On August 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-42, which provides guidance on the beginning of construction requirement as it relates to the new credit termination...more

The One Big Beautiful Bill Act: Analysis of Key Amendments to the Excise Tax Imposed on Certain Private College and University...

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). This legislation includes significant amendments to the excise tax imposed on...more

The One Big Beautiful Bill Act: Analysis of Key Provisions for the Real Estate Industry

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more

The One Big Beautiful Bill Act: Analysis of Key Provisions for Investment Funds and Sponsors

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more

The One Big Beautiful Bill Act: Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more

Treasury and IRS Release Updated Guidance on Energy Communities (UPDATED)

On June 23, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-31. This notice includes lists of information that taxpayers may use to determine whether they meet certain requirements...more

Tax Credit Implications of the One Big Beautiful Bill Act

On May 22, the U.S. House of Representatives passed an amended version of H.R. 1—the One Big Beautiful Bill Act (the Bill) — by a vote of 215-214. The House-passed version of the bill, slated to be considered by the Senate...more

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

Treasury and IRS Issue Updated Domestic Content Guidance Under IRA and First Updated Elective Safe Harbor

On January 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-08 (Notice), which provides an updated safe harbor (First Updated Elective Safe Harbor) that modifies and otherwise...more

Treasury and IRS Issue Final Regulations on Clean Electricity Production and Investment Tax Credits

On January 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published final regulations providing further guidance on the clean electricity production credit under Section 45Y and the clean...more

IRS Issues Final Regulations on Clean Hydrogen Tax Credits

The IRS and the Treasury Department issued final regulations on January 3 (Final Regulations), providing guidance on the clean hydrogen production tax credit under Section 45V (Hydrogen PTC) and the investment tax credit...more

Locke Lord Deep Dive: Treasury Issues Final Regulations Providing Guidance on Transfer of Certain Credits Under the Inflation...

On April 30, 2024, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) published Final Treasury Regulations (T.D. 9993) (the “Final Regulations”) providing guidance relating to the election...more

Locke Lord Deep Dive: Examining Proposed Regulations on Expanded ITC Under Inflation Reduction Act

On November 22, 2023, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) published Proposed Treasury Regulations (REG-132569-17) (the “Proposed Regulations”) providing long-awaited guidance and...more

Treasury Issues Proposed Regulations ‎‎on Expanded ITC Under Inflation Reduction Act, ‎Boosting ‎‎Storage, Offshore Wind

On November 17, 2023, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) issued Proposed Treasury Regulations (REG-132569-17) (the “Proposed Regulations”) providing guidance and amending...more

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