News & Analysis as of

Inflation Reduction Act (IRA) Proposed Regulation

Mitchell, Williams, Selig, Gates & Woodyard,...

Implementation of Section 45Z/Clean Fuels Production Credit: Energy Marketers of America Comments on Internal Revenue Service's...

The Energy Marketers of America (formerly, Petroleum Marketers Association of America) (“EMA”) submitted April 10th comments to the Internal Revenue Service (“IRS”) addressing its: …notice of intent to propose regulations...more

McDermott Will & Emery

IRS Roundup January 13 – 17, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...more

Jones Day

New Guidance on the Commercial EV Tax Credit

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In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...more

Jones Day

Draft Guidance on the Section 45Z Clean Fuel Production Credit

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The Department of Treasury and the IRS have released Notices 2025-10 and 2025-11, outlining intended forthcoming proposed regulations for the Section 45Z clean fuel production credit introduced by the Inflation Reduction Act...more

Holland & Knight LLP

Treasury Department, IRS Release Section 45W Clean Commercial Vehicle Guidance

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The U.S. Department of the Treasury and IRS released proposed regulations on Jan. 10, 2025, regarding the qualified commercial clean vehicle credit under Section 45W of the Internal Revenue Code, as enacted by the Inflation...more

Holland & Knight LLP

Proposed Regulations Provide Clarity on Tax Treatment of Entities Wholly Owned by Tribal Governments

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The U.S. Department of the Treasury and IRS issued the Proposed Regulations on Oct. 9, 2024, providing long-awaited guidance on entities wholly owned by Tribal governments and organized or incorporated exclusively under the...more

Mayer Brown

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

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On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) to allow certain unincorporated organizations owned by specified “applicable...more

Vinson & Elkins LLP

CAMT Touch This: Treatment of Tax Credits, Direct Pay, and Transferability under the Corporate Alternative Minimum Tax

Vinson & Elkins LLP on

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Section 45X Advanced Manufacturing Production Credit

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The Inflation Reduction Act of 2022 added the Section 45X Advanced Manufacturing Production Credit (Section 45X) to the Internal Revenue Code of 1986, as amended. Section 45X provides a credit against federal income tax for...more

Paul Hastings LLP

Proposed Regulations on the Section 30C Alternative Fuel Vehicle Refueling Property Credit

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The Section 30C Alternative Fuel Vehicle Refueling Property Credit (the “Section 30C Credit”) provides a credit against federal income tax for eligible costs of qualified alternative fuel vehicle refueling property. The...more

Eversheds Sutherland (US) LLP

Clarifying the federal tax classification of wholly owned tribal entities and the mechanics of the Section 6417 election for such...

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

Vinson & Elkins LLP

CAMT Count Me Twice: Determining CAMT AFSI in Mergers and Acquisitions

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Cadwalader, Wickersham & Taft LLP

Treasury and IRS Release Proposed Corporate Alternative Minimum Tax Regulations

On September 13, 2024, in the Federal Register, the Treasury and IRS published proposed regulations implementing the corporate alternative minimum tax (“CAMT”).  Its 182 pages (including 62 pages of preamble) describe a...more

Holland & Knight LLP

Treasury Department, IRS Release Section 30C Proposed Regulations

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The U.S. Department of the Treasury and IRS on Sept. 19, 2024, released proposed regulations under Section 30C of the Internal Revenue Code providing important clarity on the changes made by the Inflation Reduction Act (IRA)....more

Vinson & Elkins LLP

Why CAMT I Get Away From You: Losing Applicable Corporation Status Under the Corporate Alternative Minimum Tax

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Paul Hastings LLP

Treasury Issues Proposed Regulations on the Section 30C Alternative Fuel Vehicle Refueling Property Credit

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The Alternative Fuel Vehicle Refueling Property Credit available under Section 30C of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Section 30C Credit”), was originally enacted by the...more

Vinson & Elkins LLP

Charging Forward: Proposed Regulations Issued for EV Charging & Alternative Fuel Refueling Property

Vinson & Elkins LLP on

On September 18, 2024, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) (1) issued proposed regulations (the “Proposed Regulations”) providing guidance to taxpayers on the Alternative...more

Eversheds Sutherland (US) LLP

Be careful what you wish for: IRS and Treasury release goliath CAMT NPRM full of nuance and complexity

On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more

McDermott+

McDermott+ Check-Up: September 20, 2024

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Senate Judiciary Human Rights and the Law Subcommittee Holds Hearing on Georgia Abortion Ban. The field hearing examined how Georgia’s abortion ban impacts women’s health, and featured patient and physician witnesses. ...more

Holland & Knight LLP

Treasury, IRS Release Proposed Regulations Under Section 30C

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The U.S. Department of the Treasury and IRS on Sept. 18, 2024, released proposed regulations under Section 30C of the Internal Revenue Code regarding the Alternative Fuel Vehicle Refueling Property Credit. The proposed...more

Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

Vinson & Elkins LLP on

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Jones Day

Taxing Tangle: U.S. IRS Releases Guidance for Clean Hydrogen Production Tax Credit

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The U.S. Internal Revenue Service ("IRS") has released proposed regulations regarding the Clean Hydrogen Production Tax Credit introduced in the Inflation Reduction Act of 2022 ("IRA"). The proposed regulations provide more...more

Baker Botts L.L.P.

Proposed Regulations Regarding Section 48E Clean Electricity Low-Income Communities Bonus Credit Program

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On September 3, 2024, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) published proposed regulations relating to the Clean Electricity Low-Income Communities Bonus Credit Program (the...more

ASKramer Law

Energy Tax Credits for a New World Part II: Production Tax Credits and Investment Tax Credits: The Old and the New

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What is a Production Tax Credit (PTC)? A Production Tax Credit (PTC) is a per kilowatt-hour (kWh) tax credit for electricity generated by solar and other qualifying clean technologies for the first 10 years of a system’s...more

Troutman Pepper Locke

IRS Issues Final Regulations on Prevailing Wages and Registered Apprenticeship Requirements

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On June 18, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Regulations) on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing...more

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