News & Analysis as of

Comment Period Internal Revenue Code (IRC) Tax Reform

Eversheds Sutherland (US) LLP

IRS and Treasury notice proposes removal of disregarded payment loss rules and changes to dual consolidated loss rules

On August 20, 2025, the Internal Revenue Service (IRS) released Notice 2025-44 (Notice), which announced that the Department of the Treasury (Treasury) and IRS intend to issue proposed regulations that would...more

Pullman & Comley, LLC

DEEP Issues Draft Request for Proposals from Private Developers of Zero Carbon Energy Using Onshore Wind, Solar and Co-located...

Pullman & Comley, LLC on

On August 21, 2025, the Connecticut Department of Energy & Environmental Protection (DEEP) released an expedited draft Request for Proposals (RFP). The RFP seeks submissions from project developers for new, advanced-stage...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

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