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FEOC Restrictions on Energy Tax Credits: An Update

On July 1, 2025, the U.S. Senate passed a version of the One Big Beautiful Bill Act that differed significantly from the version previously passed on May 22 by the U.S. House of Representatives as H.R. 1. Front of mind for...more

Energy Tax Credit Framework Undergoes Further Changes in Senate-Approved Version of OBBB Act

On July 1, 2025, the U.S. Senate passed its version of The One Big Beautiful Bill (OBBB) Act, the massive budget bill that contains significant provisions affecting tax credits for renewable energy project development. After...more

Senate Version of One Big Beautiful Bill Act Clarifies Foreign Entity Restrictions on Renewable Energy Tax Credits

The Senate Finance Committee recently released its own draft of the “One Big Beautiful Bill Act” (the Bill) previously passed by the House as H.R. 1. Both the House and Senate versions of the Bill impose restrictions on...more

Tax Credit Transfers May Have Unexpected State Tax Consequences

One of the most celebrated features of the Inflation Reduction Act (“IRA”) is the ability to sell tax credits, including the Production Tax Credit (“PTC”) under Internal Revenue Code (“IRC”) § 45 and the Investment Tax Credit...more

IRS Takes Aim at High Earners, Large Partnerships, and Corporations Using AI

When the Inflation Reduction Act was passed last year, the legislation included massive funding increases for the Internal Revenue Service (IRS). The initial narratives regarding the funding increases focused primarily on...more

U.S. Treasury Department Seeks Input On Six Notices Related to Inflation Reduction Act

On October 5, 2022, the U.S. Department of the Treasury highlighted six separate notices requesting initial general public comments in response to specific sets of questions pertaining to climate and clean energy tax...more

Inflation Reduction Act Imposes New Tax on Buybacks

The Repurchase of Corporate Stock provision of the Inflation Reduction Act of 2022 (IRA), often called the stock-buyback provision, imposes a one percent excise tax on the repurchase or redemption of stock by covered...more

Inflation Reduction Act to Greatly Increase IRS Funding

The Inflation Reduction Act of 2022 (IRA) includes increased Internal Revenue Service (IRS) funding in the amount of approximately $80 billion over ten years. According to a Congressional Research Service report, the law...more

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