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House Enacts the Senate Legislative Text of the One Big Beautiful Bill Act

On July 3, 2025, the House approved the Senate’s legislative text (the “Senate Legislative Version”) for the budget reconciliation bill (H.R. 1, the “One Big Beautiful Bill Act”) without any changes. Thus, the final...more

United States Senate Finance Committee Makes Changes to Clean Energy Provisions of the Proposed One Big Beautiful Bill

On June 16, 2025, the US Senate Committee on Finance released its legislative text (the “Senate Finance Committee version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently...more

House Reconciliation Bill Amends Clean Energy Provisions of the IRA

On May 22, 2025, the House of Representatives passed its reconciliation bill, H.R. 1, entitled “One Big Beautiful Bill Act” (the “legislation”), which significantly amends the clean energy provisions that were enacted as part...more

Treasury Issues Final Regulations on Technology Neutral Clean Energy Projects

On January 7, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) relating to technology-neutral tax credits for clean energy...more

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) to allow certain unincorporated organizations owned by specified “applicable...more

Treasury and IRS Issue Final Regulations on Section 45X

On October 24, 2024, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) on the Section 45X Advanced Manufacturing Production Credit of the...more

Final Guidance Issued on “Foreign Entity of Concern” Criteria

On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

REITs’ Clean Energy Tax Credits Transfer Options Under IRA Clarified in Final Regulations

On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations”) concerning the election to transfer certain tax credits...more

Final Regulations Issued on Direct-Pay Elections and Transfer of Tax Credits

On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations under section 6418”) concerning the election to transfer...more

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