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IRS Releases Updated OBBBA-Related Energy Credit Guidance

On August 15, 2025, the US Department of the Treasury and the Internal Revenue Service (the “IRS”) issued Notice 2025-42 (the “August 2025 Notice”), providing critical guidance on the determination of when construction begins...more

House Enacts the Senate Legislative Text of the One Big Beautiful Bill Act

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

United States Senate Finance Committee Makes Changes to Clean Energy Provisions of the Proposed One Big Beautiful Bill

On June 16, 2025, the US Senate Committee on Finance released its legislative text (the “Senate Finance Committee version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently...more

House Reconciliation Bill Amends Clean Energy Provisions of the IRA

On May 22, 2025, the House of Representatives passed its reconciliation bill, H.R. 1, entitled “One Big Beautiful Bill Act” (the “legislation”), which significantly amends the clean energy provisions that were enacted as part...more

From Extraction to Smelting: President Trump Issues Executive Order Aiming to Increase American Mineral Production

Those in the critical minerals industry have been waiting to see what President Donald Trump’s next move would be after his “Unleashing American Energy” Executive Order on January 20, 2025 (the “January Executive Order”),...more

Treasury Issues Final Regulations on Technology Neutral Clean Energy Projects

On January 7, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) relating to technology-neutral tax credits for clean energy...more

Treasury and IRS Issue Final Regulations on Section 45X

On October 24, 2024, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) on the Section 45X Advanced Manufacturing Production Credit of the...more

Bipartisan Group of Senators Introduces Bill to Prevent Chinese Companies from Using Certain American Tax Credits

On July 31, 2024, Senators Jon Ossof (D-GA), Sherrod Brown (D-OH), Bill Cassidy (R-LA), and Rick Scott (R-FL) introduced the bipartisan American Tax Dollars for American Solar Manufacturing Act. The bill aims to “prevent...more

USTR Invites Public Comments on WTO Dispute Settlement Proceeding Regarding China’s Allegations That Certain Tax Credits Under the...

On August 27, 2024, the Office of the U.S. Trade Representative (USTR) published a notice to the Federal Register “invit[ing] written comments from the public concerning the issues raised” by China in its dispute before the...more

Outlook for Energy and Tax Policy in 2025

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

Final Regulations Issued on Prevailing Wage and Apprenticeship Requirements under the Inflation Reduction Act

On June 18, 2024, the US Internal Revenue Service (“IRS”) and Department of the Treasury (“Treasury”) issued final regulations (“Final Regulations”) establishing rules for taxpayers intending to satisfy the prevailing wage...more

Final Guidance Issued on “Foreign Entity of Concern” Criteria

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

Final Regulations Issued on Direct-Pay Elections and Transfer of Tax Credits

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

Proposed Regulations on Section 45X Advanced Manufacturing Production Tax Credit

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

US Treasury to Propose Regulations on Domestic Content Bonus Credit

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

Recent Legislative Proposals Could Drastically Change US Energy Taxation

Over the past number of weeks, a variety of legislative proposals, from both sides of the aisle, have been released that, if enacted, could drastically impact the US energy industry and, in many cases, the taxation of energy...more

Recent Legislative Proposals Could Drastically Change US Energy Taxation

Over the past number of weeks, a variety of legislative proposals, from both sides of the aisle, have been released that, if enacted, could drastically impact the US energy industry and, in many cases, the taxation of energy...more

Energy Tax Implications of New Infrastructure and Tax Plans

The American Jobs Plan - On March 31, 2021, the Biden administration released the American Jobs Plan (the “Infrastructure Plan”), which is a proposal that, if ultimately enacted, aims to modernize outdated infrastructure,...more

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