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The One Big Beautiful Bill Act: An Initial Analysis of Key Tax Proposals

On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more

The Tax Implications of Trump’s Recent Executive Actions

President Donald Trump has issued a series of executive orders with significant tax implications. The moves underscore the administration’s commitment to influencing tax policies, regulatory frameworks and trade practices as...more

Possible Tax Reforms Could Run Up Against Deficit and Debt Concerns

Key Points - - Many of the tax reform suggestions President-elect Trump floated during the campaign would result in significant revenue loss, which could mean they will face resistance from Republicans concerned about...more

The IRS Takes Aim at Basis Adjustments in Partnership Transactions

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

Transferability: IRS Guidance Energizes Participation in a New Tax Credit Monetization Strategy

The Inflation Reduction Act (IRA) of 2022 reflected a push by Congress and the Biden administration to address climate change by broadening the applicability of tax credits traditionally available for renewable energy to new...more

Monetizing Energy Tax Credits Is Clearly Tax-Free, Unless It’s Not

The Inflation Reduction Act (IRA) of 2022 includes an estimated $370 billion of energy-related credits, marking a historic effort to reduce greenhouse gas emissions. Significant new provisions include direct payment and...more

Senate Passes Landmark Bill With Climate, Tax, Energy and Health Care Implications

On August 7, 2022, the Senate passed the Inflation Reduction Act (the Act), which is expected to have a significant impact on climate, tax and health care policy in the United States. The result of intense negotiations among...more

Guidance on Carbon Capture and Sequestration Tax Credit Provides Clarity for Developers and Investors

The Treasury Department and the Internal Revenue Service (IRS) recently released long-awaited proposed regulations regarding the carbon capture and sequestration tax credit provided under Section 45Q of the Internal Revenue...more

IRS Proposes New Section 382 Regulations To Further Limit Use of Tax Losses

On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more

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