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Impact of the One Big Beautiful Bill Act on Tax-Exempt Organizations

President Donald Trump signed into law the One Big Beautiful Bill Act (OBBB) on July 4, 2025, marking a victory for his administration's ability to advance major policy priorities in his second term domestic agenda, including...more

IRS Releases 2025 Inflation Adjustments for Sections 45U, 45V and 45Z

The IRS on July 21, 2025, released Notice 2025-37, announcing the inflation-adjusted credit amounts for calendar year 2025 applicable to tax credits available under Internal Revenue Code Sections 45U, 45V and 45Z, which were...more

Tribal Tax Provisions In (and Missing From) the One Big Beautiful Bill

Signed into law by President Donald Trump on July 4, 2025, the One Big Beautiful Bill Act (OBBB) contains extensive revisions to the U.S. Internal Revenue Code (Code). (For a comprehensive analysis of the bill, see Holland &...more

Executive Order Requires Treasury Guidance on Wind, Solar and FEOC Rules for Energy Tax Credits

President Donald Trump issued an executive order (EO) on July 7, 2025, regarding "Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources." The EO follows the signing into law of the One Big...more

IRS Issues Updates for Energy Community Bonus Tax Credit

The IRS released additional guidance on June 23, 2025, in the form of Notice 2025-31 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...more

Senate Moves to Scale Back Clean Energy Tax Credits Under Inflation Reduction Act

The U.S. Senate Committee on Finance on June 16, 2025, released legislative text within its jurisdiction for inclusion in the Senate Republicans' budget reconciliation bill. This is the Senate's response to the One Big...more

Eyes on Energy Tax: IRS Releases 2025 Section 45 Production Tax Credit Amounts

The IRS on May 23, 2025, released 2025 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code. The guidance provides that: Section 45 allows a renewable energy PTC for generating electricity from...more

House of Representatives Moves to Scale Back Clean Energy Tax Credits Under IRA

The U.S. House of Representatives passed the "One Big Beautiful Bill" on May 22, 2025, by a vote along party lines. The bill will now be taken up by the U.S. Senate. This Holland & Knight alert summarizes certain key...more

IRS Releases Form 4255 to Report Prevailing Wage and Apprenticeship Penalty Amounts

The IRS recently released an updated Form 4255, Certain Credit Recapture, Excessive Payments, and Penalties, which is used to report the amount due for certain credit recaptures, excessive payments, excessive credit transfers...more

Interim Final Rule Clarifies Tribal Entities Not Subject to Corporate Transparency Act

The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury charged with administering the Corporate Transparency Act (CTA), issued an interim final rule on March 21, 2025, that exempts...more

Navigating the Domestic Content Requirements Under Evolving IRS Guidance

The IRS issued Notice 2025-08 on Jan. 16, 2025, which provides updated guidance regarding the domestic content requirements under Sections 45, 48, 45Y and 48E of the Internal Revenue Code – the investment tax credits and...more

Questions and Answers: Initial Section 45Z Clean Fuel PTC Guidance

The U.S. Department of the Treasury and IRS on Jan. 10, 2025, released initial guidance regarding the production tax credit (PTC) for clean fuels under Section 45Z of the Internal Revenue Code, as enacted by the Inflation...more

Key Highlights of the Section 761 Final Regulations and Impact on Section 6417 Direct Payments

Under Section 6417 of the Code, as enacted by the Inflation Reduction Act (IRA), certain taxpayers that fall within the statutory definition of "applicable entities" are allowed to elect to receive a direct payment (i.e.,...more

Treasury Department, IRS Release Section 45V Clean Hydrogen PTC Final Regulations

The U.S. Department of the Treasury and IRS on Jan. 3, 2025, released Final Regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

Treasury Department, IRS Release Section 45Z Clean Fuel PTC Guidance

The U.S. Department of the Treasury and IRS released initial guidance on Jan. 10, 2025, regarding the production tax credit (PTC) for clean fuels under Section 45Z of the Internal Revenue Code, as enacted by the Inflation...more

Proposed Regulations Provide Clarity on Tax Treatment of Entities Wholly Owned by Tribal Governments

The U.S. Department of the Treasury and IRS issued the Proposed Regulations on Oct. 9, 2024, providing long-awaited guidance on entities wholly owned by Tribal governments and organized or incorporated exclusively under the...more

Key Highlights of the Section 48 ITC Final Regulations

The U.S. Department of the Treasury and IRS on Dec. 12, 2024, issued Final Regulations regarding the investment tax credit (ITC) for Section 48 of the Internal Revenue Code, including the ITC for energy generation, energy...more

Treasury Department, IRS Release Section 45V Clean Hydrogen PTC Final Regulations

The U.S. Department of the Treasury and IRS on Jan. 3, 2025, released final regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

Highlights of Final Regulations Under Section 45X Advanced Manufacturing Tax Credit

The U.S. Department of the Treasury and IRS on Oct. 28, 2024, published final regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (Final Regulations)....more

Treasury Department, IRS Release Section 45X Advanced Manufacturing Production Credit Final Regulations

The U.S. Department of the Treasury and IRS on Oct. 24, 2024, released Final Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. The Final Regulations are effective 60...more

Treasury Department, IRS Release Section 30C Proposed Regulations

The U.S. Department of the Treasury and IRS on Sept. 19, 2024, released proposed regulations under Section 30C of the Internal Revenue Code providing important clarity on the changes made by the Inflation Reduction Act (IRA)....more

Treasury, IRS Release Proposed Regulations Under Section 30C

The U.S. Department of the Treasury and IRS on Sept. 18, 2024, released proposed regulations under Section 30C of the Internal Revenue Code regarding the Alternative Fuel Vehicle Refueling Property Credit. The proposed...more

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

IRS Releases Long-Awaited Section 45Q LCA Procedures

The IRS on July 24, 2024, released Notice 2024-60, which provides Section 45Q guidance for utilization of carbon dioxide and other carbon oxides. The Notice addresses the information that must be included in the required life...more

The (Uncertain) Application of the Corporate Transparency Act to Tribal Entities

The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury (Treasury Department) charged with administering the Corporate Transparency Act (the CTA), on Aug. 1, 2024, held a Tribal...more

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