Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
7/16/2025
/ Business Taxes ,
Compensation ,
Corporate Taxes ,
Employee Benefits ,
Executive Compensation ,
Federal Budget ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Loper Bright Enterprises v Raimondo ,
New Legislation ,
SCOTUS ,
Tax Court ,
Tax Reform ,
Taxation ,
Trump Administration
On July 2, 2025, the Tax Court issued its unanimous reviewed opinion in JM Assets, LP v. Commissioner, 165 T.C. 1. It held that the Service did not timely issue a final partnership adjustment (FPA) to JM Assets, LP (JM...more
7/11/2025
/ Administrative Authority ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
Loper Bright Enterprises v Raimondo ,
Regulatory Agencies ,
SCOTUS ,
Statutory Interpretation ,
Tax Court ,
Taxation
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On July 1, 2025, the Senate passed One Big Beautiful Bill (OBBB) in a 51-50 vote, with Vice President J.D. Vance casting a tiebreaker vote. Although the House of Representatives previously passed its own version of OBBB (see...more
7/7/2025
/ China ,
Clean Energy ,
Energy Policy ,
Energy Projects ,
Federal Budget ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
New Legislation ,
Popular ,
Renewable Energy ,
Tax Credits ,
Trump Administration
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On May 22, 2025, the House of Representatives passed the highly anticipated budget reconciliation bill, referred to as the “One Big Beautiful Bill,” with revisions from the House Rules Committee. On May 21, 2025, the House...more
The House of Representatives narrowly passed the One Big Beautiful Bill along party lines. The proposed bill would terminate or otherwise make significant changes to several of the energy tax credits created or expanded by...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
5/21/2025
/ Business Taxes ,
EBITDA ,
Employee Benefits ,
Employee Retention ,
Excise Tax ,
Legislative Agendas ,
New Legislation ,
Proposed Legislation ,
Reporting Requirements ,
Senate Committees ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Reform ,
U.S. House ,
Ways and Means Committee
On May 12, 2025, the Republicans from the House Committee on Ways and Means released an updated draft tax bill. Several of the provisions in the draft would affect tax-exempt organizations. The bill will almost certainly...more
5/19/2025
/ Charitable Deductions ,
Colleges ,
Excise Tax ,
Legislative Agendas ,
Private Foundations ,
Proposed Legislation ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
U.S. House ,
Universities ,
Unrelated Business Income Tax ,
Ways and Means Committee
On May 12, 2025, the Republicans on the House Committee on Ways and Means released a draft bill showing their tax plan for the budget reconciliation legislation. The legislation will likely undergo significant changes as it...more
5/15/2025
/ Amortization ,
Bonus Depreciation ,
Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
EBITDA ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Legislation ,
Research and Development ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Ways and Means Committee
On October 7, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) clarifying the federal tax classification of certain entities wholly owned by...more
10/24/2024
/ Entity Classification ,
Income Taxes ,
Indian Reorganization Act ,
Inflation Reduction Act (IRA) ,
IRS ,
New Regulations ,
Proposed Regulation ,
Regulatory Agenda ,
Tribal Corporations ,
Tribal Governments ,
U.S. Treasury
On July 24, 2024, the IRS issued Notice 2024-60, which sets forth the procedures for taxpayers to follow when claiming Section 45Q credits based on the “utilization” of carbon oxide. Taxpayers claiming credits based on...more
On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more
[unable to retrieve full-text content]On April 25, 2024, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations on the transferability of certain tax credits under the...more
On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more
4/11/2024
/ Federal Taxes ,
Income Taxes ,
Investment Tax Credits ,
IRS ,
Manufacturing Facilities ,
Partnerships ,
Registration Requirement ,
S-Corporation ,
Semiconductors ,
Tax Liability ,
U.S. Treasury
The Inflation Reduction Act of 2022 established sustainable aviation fuel (SAF) tax credits to benefit United States producers and importers of certain fuel mixtures containing SAF. On December 15, 2023, the Internal Revenue...more
On December 26, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pertaining to the clean hydrogen production credit (Clean Hydrogen...more
12/29/2023
/ Anti-Abuse Rule ,
Clean Energy ,
Electricity ,
Energy Projects ,
Energy Sector ,
Energy Storage ,
Hydrogen Power ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Utilities Sector
On November 17, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) relating to eligible energy property that qualifies for the section 48...more
On August 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) on the clean energy prevailing wage and apprenticeship (PWA) requirements...more
9/14/2023
/ Apprenticeships ,
Clean Energy ,
Climate Change ,
Davis-Bacon Act ,
Energy Projects ,
Energy Sector ,
Federal Contractors ,
Inflation Reduction Act (IRA) ,
IRS ,
Labor Regulations ,
Prevailing Wages ,
Proposed Regulation ,
Renewable Energy ,
Subcontractors ,
Tax Credits ,
U.S. Treasury
On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more
7/3/2023
/ Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
Transfer of Interest ,
U.S. Treasury
On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a package of much-awaited guidance (the Guidance) consisting of (i) proposed regulations addressing the tax credit...more
6/19/2023
/ Comment Period ,
Energy Sector ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
IRS ,
Manufacturers ,
Monetization ,
New Guidance ,
Registration Requirement ,
Semiconductors ,
Tax Credits ,
Technology Sector ,
Transfer of Interest ,
U.S. Treasury
On May 12, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2023-38 to provide guidance on the domestic content requirements under IRC sections 45, 45Y, 48, and 48E....more
5/15/2023
/ Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
New Guidance ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
On April 4, 2023, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-29(the Notice) to provide additional guidance on energy community bonus tax credits under IRC sections 45, 45Y,...more
4/11/2023
/ CERCLA ,
Coal-Fired Plants ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy ,
Safe Harbors ,
Tax Credits
On April 4, 2023, the IRS and the Department of Treasury released Notice 2023-29 (the Notice), which provides that proposed regulations are forthcoming regarding the energy community bonus tax credits under IRC sections 45,...more
On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (Service) issued Notice 2023-17 (Notice), establishing the 48(e) Low-Income Communities Bonus Credit Program (Program) with respect...more
3/13/2023
/ Community Development ,
Energy Projects ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
New Guidance ,
Solar Energy ,
Tribal Lands ,
U.S. Treasury ,
Wind Power