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Treasury Issues Proposed Regulations on the Section 30D Clean Vehicle Tax Credit’s Foreign Entity of Concern Rules

The Inflation Reduction Act of 2022 brought about modifications to the clean vehicle tax credit available under Section 30D of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Clean Vehicle...more

Treasury Issues Proposed Regulations on the Definition of “Energy Property” and Rules Applicable to the Section 48 Energy Credit

The Inflation Reduction Act of 2022 made significant modifications and additions to the energy credit available under Section 48 of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Section...more

Treasury Issues Long-Awaited Wage and Apprenticeship Regulations for Energy Tax Credits

The Inflation Reduction Act of 2022 introduced significant changes to the renewable energy tax credit landscape. One of the most notable of these changes, in addition to the broader goals of combating climate change and...more

Treasury and IRS Provide Guidance on Energy Tax Credit Direct Payment Elections

The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more

Treasury and IRS Issue Long-Awaited Guidance on Energy Tax Credit Transfers

The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code of 1986, as amended (the “Code”), which allows taxpayers to elect to transfer all or any portion of certain energy tax credits to an...more

Treasury Issues Additional Guidance on Low-Income Community Bonus Credit

On June 1, 2023, the Treasury Department (“Treasury”) issued a notice of proposed rulemaking including proposed rules (the “Proposed Rules”) regarding the “Low-Income Communities Bonus Credit Program” established by the...more

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

Treasury Issues Final Guidance on Housing Tax Credit Income Averaging Rule; IRS Extends Deadlines

On October 7, 2022, Treasury issued final and temporary regulations on the income averaging rules for the low-income housing tax credit (“LIHTC”) under Section 42 of the U.S. Internal Revenue Code of 1986, as amended (the...more

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