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IRS Releases 2025 Inflation Adjustments for Sections 45U, 45V and 45Z

The IRS on July 21, 2025, released Notice 2025-37, announcing the inflation-adjusted credit amounts for calendar year 2025 applicable to tax credits available under Internal Revenue Code Sections 45U, 45V and 45Z, which were...more

A Look at the International Tax Changes in the One Big Beautiful Bill Act

The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more

Executive Order Requires Treasury Guidance on Wind, Solar and FEOC Rules for Energy Tax Credits

President Donald Trump issued an executive order (EO) on July 7, 2025, regarding "Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources." The EO follows the signing into law of the One Big...more

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

IRS Issues Updates for Energy Community Bonus Tax Credit

The IRS released additional guidance on June 23, 2025, in the form of Notice 2025-31 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...more

Registration Opens for Information on Trump Gold Card Residency Permit

As of June 12, 2025, individuals and businesses can register to receive information on the Trump Gold Card – a proposed alternative or possible replacement to the EB-5 visa, also known as the Immigrant Investor Visa. ...more

Senate Moves to Scale Back Clean Energy Tax Credits Under Inflation Reduction Act

The U.S. Senate Committee on Finance on June 16, 2025, released legislative text within its jurisdiction for inclusion in the Senate Republicans' budget reconciliation bill. This is the Senate's response to the One Big...more

Another Surprise in the One Big Beautiful Bill: Excise Tax on Remittances

As Republicans in the U.S. Senate now consider the reconciliation bill, they will need to consider what tax provisions contained in the One Big Beautiful Bill (OBBB), passed by the U.S. House of Representatives on May 22,...more

Eyes on Energy Tax: IRS Releases 2025 Section 45 Production Tax Credit Amounts

The IRS on May 23, 2025, released 2025 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code. The guidance provides that: Section 45 allows a renewable energy PTC for generating electricity from...more

House of Representatives Moves to Scale Back Clean Energy Tax Credits Under IRA

The U.S. House of Representatives passed the "One Big Beautiful Bill" on May 22, 2025, by a vote along party lines. The bill will now be taken up by the U.S. Senate. This Holland & Knight alert summarizes certain key...more

IRS Releases Form 4255 to Report Prevailing Wage and Apprenticeship Penalty Amounts

The IRS recently released an updated Form 4255, Certain Credit Recapture, Excessive Payments, and Penalties, which is used to report the amount due for certain credit recaptures, excessive payments, excessive credit transfers...more

Navigating the Domestic Content Requirements Under Evolving IRS Guidance

The IRS issued Notice 2025-08 on Jan. 16, 2025, which provides updated guidance regarding the domestic content requirements under Sections 45, 48, 45Y and 48E of the Internal Revenue Code – the investment tax credits and...more

Questions and Answers: Initial Section 45Z Clean Fuel PTC Guidance

The U.S. Department of the Treasury and IRS on Jan. 10, 2025, released initial guidance regarding the production tax credit (PTC) for clean fuels under Section 45Z of the Internal Revenue Code, as enacted by the Inflation...more

A Look at President Trump's America First Trade Policy Executive Order and International Tax

On his first day in office, among the numerous Executive Orders (EO) released, President Donald Trump announced the America First Trade Policy EO designed to prioritize American interests in international trade and tax and,...more

Key Highlights of the Section 761 Final Regulations and Impact on Section 6417 Direct Payments

Under Section 6417 of the Code, as enacted by the Inflation Reduction Act (IRA), certain taxpayers that fall within the statutory definition of "applicable entities" are allowed to elect to receive a direct payment (i.e.,...more

Treasury Department, IRS Release Section 45V Clean Hydrogen PTC Final Regulations

The U.S. Department of the Treasury and IRS on Jan. 3, 2025, released Final Regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

Treasury Department, IRS Release Section 45Z Clean Fuel PTC Guidance

The U.S. Department of the Treasury and IRS released initial guidance on Jan. 10, 2025, regarding the production tax credit (PTC) for clean fuels under Section 45Z of the Internal Revenue Code, as enacted by the Inflation...more

Key Highlights of the Section 48 ITC Final Regulations

The U.S. Department of the Treasury and IRS on Dec. 12, 2024, issued Final Regulations regarding the investment tax credit (ITC) for Section 48 of the Internal Revenue Code, including the ITC for energy generation, energy...more

Final Regulations Issued on Penalty Supervisory Approval

More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

Treasury Department, IRS Release Section 45V Clean Hydrogen PTC Final Regulations

The U.S. Department of the Treasury and IRS on Jan. 3, 2025, released final regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

IRS Notifies Thousands of Taxpayers After Personal Information Disclosed

The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more

Elections Make Budget Reconciliation a Tool for Significant Legislation Early Next Year

Following the results of the 2024 elections, Republicans will have unified control of the federal government with President-Elect Donald Trump's inauguration on Jan. 20, 2025, and the seating of the 119th Congress on Jan. 3,...more

Highlights of Final Regulations Under Section 45X Advanced Manufacturing Tax Credit

The U.S. Department of the Treasury and IRS on Oct. 28, 2024, published final regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (Final Regulations)....more

Treasury Department Issues Final Section 48D Guidance on CHIPS Act Semiconductor Tax Incentive

The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code (Code) to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the U.S. The credit is equal to...more

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