OVERVIEW OF THE REMITTANCE TRANSFER EXCISE TAX -
Do you effect transfers of funds for US residents to recipients abroad? If so, you should review the provision of the “One Big Beautiful Bill Act” (“OBBBA”) that imposes a...more
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
The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier...more
6/19/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Budget Reconciliation ,
Foreign Tax ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Proposed Legislation ,
Public Policy ,
Senate Finance Committee ,
Tax Rates ,
Tax Reform ,
Withholding Tax
On December 4, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations, TD 10015, (the “Final Regulations”), which provide guidance on the definition of energy...more
While we await the outcome of the upcoming US elections, stakeholders in the energy tax and policy space should recognize that, regardless of the outcome of the election, there will be plenty of activity in the energy sector...more
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
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
2025 may well be the most consequential year in the history of US tax policy, at least since the establishment of the income tax through the 16th Amendment in 1913. While the US has a long history of enacting tax policies...more
On December 14, 2023, the Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed regulations to implement the Section 45X advanced manufacturing production credit established by the...more
1/3/2024
/ Batteries ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Minerals ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Solar Energy ,
Tax Credits ,
U.S. Treasury ,
Wind Power
On May 12, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on the domestic content bonus credit for certain clean energy...more