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New Guidance on the Commercial EV Tax Credit

In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...more

Draft Guidance on the Section 45Z Clean Fuel Production Credit

The Department of Treasury and the IRS have released Notices 2025-10 and 2025-11, outlining intended forthcoming proposed regulations for the Section 45Z clean fuel production credit introduced by the Inflation Reduction Act...more

Final Regulations Issued in Final Days of Congress: Clean Hydrogen Production Tax Credit

The Department of Treasury and the Internal Revenue Service issued final regulations regarding the Section 45V clean hydrogen production credit....more

Final Regulations Clarify the Investment Tax Credit Rules

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations for the investment tax credit under section 48, providing guidance for projects that start construction by December 31, 2024....more

Final Regulations Expand Access to "Direct Pay" Elections for Energy Credits

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more

Final Regulations Clarify Requirements for the Advanced Manufacturing Production Credit

The Department of Treasury and the Internal Revenue Service ("IRS") issued final regulations regarding the advanced manufacturing production tax credit....more

Taxing Tangle: U.S. IRS Releases Guidance for Clean Hydrogen Production Tax Credit

The U.S. Internal Revenue Service ("IRS") has released proposed regulations regarding the Clean Hydrogen Production Tax Credit introduced in the Inflation Reduction Act of 2022 ("IRA"). The proposed regulations provide more...more

Treasury Department Finalizes 1% Corporate Stock Buyback Tax Reporting Rules

The Background: The U.S. Treasury Department ("Treasury") issued regulations finalizing the reporting requirements on the 1% corporate stock buyback tax and starting the clock on the tax's first filing and payment deadline....more

Proposed Treasury Regulations Provide Guidance on New Clean Electricity Production and Investment Tax Credits

The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Administration Finalizes Regulations on Clean Energy Tax Credit Transfers

The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more

Proposed Guidance Clarifies "Foreign Entity of Concern" Restrictions for Clean Vehicle Credit

New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...more

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Guidance Clarifies Requirements for Energy Tax Credits' Domestic Content Bonus

The U.S. Department of the Treasury has issued interim guidance outlining forthcoming proposed regulations regarding the domestic content bonus credit available to clean energy projects under the Inflation Reduction Act of...more

Proposed Regulations Address Deductibility of Business Interest Expense - Important guidance issued on the new 30 percent...

On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more

Proposed Treasury Regulations Permit Foreign Subsidiary Credit Support for U.S. Multinational Financings

The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign corporate subsidiary ("CFC") for deemed dividends triggered when the CFC provides...more

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