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IRS and Treasury Release Final Rules for Technology-Neutral Clean Electricity Credits Under Sections 45Y and 48E

The Inflation Reduction Act of 2022 introduced the Code Section 45Y production tax credit (CEPTC) for facilities that generate clean electricity with zero greenhouse gas (GHG) emissions and the Code Section 48E investment tax...more

Treasury and IRS Finalize Clean Hydrogen Production Credit Regulations

The Inflation Reduction Act of 2022 added the Section 45V production tax credit for the production of clean hydrogen (Section 45V) to the Internal Revenue Code of 1986, as amended. Section 45V provides a credit against...more

Treasury and IRS Release Final Regulations on Section 45X Advanced Manufacturing Production Credit

The Inflation Reduction Act of 2022 added the Section 45X Advanced Manufacturing Production Credit (Section 45X) to the Internal Revenue Code of 1986, as amended. Section 45X provides a credit against federal income tax for...more

Proposed Regulations on the Section 30C Alternative Fuel Vehicle Refueling Property Credit

The Section 30C Alternative Fuel Vehicle Refueling Property Credit (the “Section 30C Credit”) provides a credit against federal income tax for eligible costs of qualified alternative fuel vehicle refueling property. The...more

Treasury Issues Proposed Regulations on the Section 30C Alternative Fuel Vehicle Refueling Property Credit

The Alternative Fuel Vehicle Refueling Property Credit available under Section 30C of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Section 30C Credit”), was originally enacted by the...more

Treasury and IRS Release Final Regulations on Direct Pay

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 make an elective payment, which will treat certain eligible...more

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

Digital Asset Payment Processors Will be Required to Report Consumers’ Digital Asset Transactions

The Internal Revenue Service and Treasury Department have issued long-awaited Proposed Regulations for parties that will be required to report transactions involving digital assets. These newly identified parties will need to...more

IRS Issues Proposed Regulations for Digital Asset Reporting

The Internal Revenue Service and Treasury Department have issued long-awaited Proposed Regulations for parties that will be required to report transactions involving digital assets. These newly identified parties will need to...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

IRS Delays Reporting Requirements on Digital Assets for “Brokers” But Not Businesses that Receive Digital Assets in Excess of...

The Infrastructure Investment and Jobs Act (H.R. 3684), (“Infrastructure Law”) was passed in 2021, and contained two provisions that target the reporting of digital assets....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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