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Sustainability and ESG Advisory Practice Update, April 2024

We are pleased to share the April 2024 issue of Wilson Sonsini's Sustainability and ESG Advisory Practice Update. Each issue combines news, key legal developments, and resources related to sustainability and environmental,...more

Treasury and IRS Propose Supplemental Notice Regarding Clean Hydrogen Production Tax Credit Regulations

On April 10, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of proposed rulemaking (the Supplemental Regulations) to supplement the Clean Hydrogen Production Tax...more

Sustainability and ESG Advisory Practice Update, March 2024

We are pleased to share the March 2024 issue of Wilson Sonsini’s Sustainability and ESG Advisory Practice Update. Each issue combines news, key legal developments, and resources related to sustainability and environmental,...more

Treasury and IRS Release Proposed and Final Regulations on Direct Pay Elections

On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more

Sustainability and ESG Advisory Practice Update, January-February 2024

We are pleased to share the January-February 2024 issue of Wilson Sonsini's Sustainability and ESG Advisory Practice Update. Each issue combines news, key legal developments, and resources related to sustainability and...more

Treasury and IRS Release Notice of Forthcoming Proposed Regulations on Section 30C Alternative Fuel Vehicle Refueling Property...

On January 19, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-20, a notice of forthcoming proposed rulemaking (Notice) regarding the alternative fuel vehicle...more

Treasury and IRS Release Proposed Regulations on Section 45V Hydrogen Production Tax Credit

On December 22, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) regarding the Clean Hydrogen Production credit...more

Sustainability and ESG Advisory Practice Update, December 2023

We are pleased to share the December 2023 issue of Wilson Sonsini’s Sustainability and ESG Advisory Practice Update. Each issue combines news, key legal developments, and resources related to sustainability and environmental,...more

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

On December 15, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) regarding the advanced manufacturing production...more

Treasury and IRS Release Long-Awaited Proposed Regulations on Section 48 Investment Tax Credits

On November 17, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) regarding the investment tax credit (ITC) under...more

Sustainability and ESG Advisory Practice Update, November 2023

We are pleased to share the November 2023 issue of Wilson Sonsini's Sustainability and ESG Advisory Practice Update. Each issue combines news, key legal developments, and resources related to sustainability and environmental,...more

Treasury and IRS Release Proposed Regulations Regarding the Prevailing Wage and Apprenticeship Requirements

On August 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of proposed rulemaking and accompanying frequently asked questions (Proposed Regulations) regarding the...more

Treasury and IRS Release Proposed Rules Regarding Direct Payment and Transferability of Certain Energy Tax Credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released two notices of proposed rulemaking regarding the direct payment of certain energy tax credits under Section 6417 of...more

IRS Releases New Proposed Rules for the Low-Income Communities Bonus Credit for the Investment Tax Credit

On May 31, 2023, the Department of Treasury (Treasury) and Internal Revenue Service (IRS) released proposed rules that set forth application and eligibility criteria for the low-income communities bonus credit investment...more

IRS Releases Preliminary Guidance on the IRA Domestic Content Bonus Credit

On May 12, 2023, the Internal Revenue Service (IRS) released long-awaited guidance on the domestic content bonus credit under the Inflation Reduction Act of 2022 (IRA). Specifically, the IRS released Notice 2023-38 regarding...more

Federal Circuit Reverses and Remands Alta Wind Case Holding that a Portion of the Asserted Section 1603 Basis May be Allocable to...

In a case decided on July 27, 2018, the U.S. Court of Appeals for the Federal Circuit (the Court of Appeals) reversed the Court of Federal Claims' (the Claims Court) decision in Alta Wind I Owner-Lessor C et al v. United...more

IRS Issues Notice 2018-59: "Begun Construction" Guidance for the Investment Tax Credit

On June 22, 2018, the IRS issued Notice 2018-59 (ITC Guidance), providing long-awaited guidance on the "begun construction" requirements for facilities qualifying for the Section 48 investment tax credit (ITC). The ITC is a...more

Senate Finance Committee Releases Its Version of the Tax Cuts and Jobs Act

After releasing summaries and various Chairman's marks, the Senate Finance Committee ("SFC") approved its tax reform bill, the "Tax Cuts and Jobs Act," on November 16, 2017 and released the legislative text of the bill to the...more

House Committee on Ways and Means Releases Tax Cuts and Jobs Act

On November 2, 2017, the House Committee on Ways and Means, led by Republican Chairman Kevin Brady, released H.R. 1, the "Tax Cuts and Jobs Act." The House Committee is expected to mark up the bill beginning on November 6,...more

President Trump Issues Executive Order on Climate Change

On March 28, 2017, President Donald Trump issued an executive order that significantly rolls back climate change policy enacted under the Obama administration and requires review of agency actions that may negatively impact...more

IRS Provides an ITC Safe Harbor for Projects Under Energy Savings Performance Contract Energy Sales Agreements with Release of...

On January 19, 2017, the IRS released an advance version of Revenue Procedure 2017-19, which provides a safe harbor (the "Safe Harbor") under which the IRS will not challenge the treatment of an Energy Savings Performance...more

IRS Issues Proposed Regulations on Centralized Partnership Audit Regime

On January 18, 2017, the IRS released proposed regulations (the "Proposed Regulations") to implement Section 1101 of the Bipartisan Budget Act of 2015 (BBA),1 which replaces the current rules governing partnership...more

IRS Issues Notice 2017-04, Further Clarifying and Extending the "Begun Construction" Requirements for ITCs and PTCs

On December 15, 2016, the IRS issued Notice 2017-04, which clarifies and extends certain "begun construction" requirements for facilities qualifying for the Section 45 production tax credit (PTC) for which construction must...more

The Unwind: ‘I Don’t Want It’

In the inaugural column of ‘‘Power and Taxes,’’ we discussed the tensions surrounding the requirement that an investor be an owner when a project is placed in service in order to qualify for the investment tax credit under...more

Final IRS Regulations Clarify That Certain Solar Assets May Qualify as Real Property for REIT Purposes

On August 30, 2016, the IRS issued final regulations that clarify and expand the definition of "real property" for purposes of qualifying as a real estate investment trust (REIT). The final regulations substantially follow...more

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