News & Analysis as of

Inflation Reduction Act (IRA) Tax Liability U.S. Treasury

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

Rivkin Radler LLP on

An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may make an elective payment, which will treat certain eligible...more

Troutman Pepper Locke

IRS Issues Final Regulations on Direct Pay

Troutman Pepper Locke on

On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the...more

Jones Day

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

Jones Day on

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Morrison & Foerster LLP

Turning Tax Credits into Cash: IRS and Treasury Release Proposed Direct Pay and Transferability Regulations

On June 14, 2023, the IRS and Treasury Department released proposed regulations regarding the monetization of certain clean energy tax credits, as well as temporary regulations regarding mandatory information and registration...more

Troutman Pepper Locke

Treasury and IRS Release Additional Guidance on Energy Community Enhancements Under IRA

Troutman Pepper Locke on

On June 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-45 and Notice 2023-47. Notice 2023-45 clarifies requirements for a brownfield site energy community safe harbor provided...more

Mayer Brown

US Treasury to Propose Regulations on Domestic Content Bonus Credit

Mayer Brown on

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

Brownstein Hyatt Farber Schreck

IRS Releases Long-Awaited Spending Plan for $80 Billion in New Inflation Reduction Act Funding

On Thursday, April 6, the Treasury Department and Internal Revenue Service (IRS) issued their long-term Strategic Operating Plan (SOP), outlining how the IRS intends to spend $79.4 billion in funding provided by the Inflation...more

Wilson Sonsini Goodrich & Rosati

The IRS Releases Preliminary Guidance on the IRA Energy Community Bonus Credit

On April 4, 2023, the Internal Revenue Service (IRS) released Notice 2023-29 (which follows an earlier notice [Notice 2022-51] released in October 2022 soliciting comments on bonus tax credit requirements) regarding certain...more

Brownstein Hyatt Farber Schreck

Interim Guidance on Book-Minimum Tax and Stock Buyback Excise Tax

The Treasury Department and the Internal Revenue Service (IRS) released initial guidance on Dec. 27, 2022, concerning two corporate tax increases included in the climate and energy reconciliation bill commonly known as the...more

Littler

New Federal Tax Credits Require Compliance with New Prevailing Wage and Apprenticeship Mandates on Clean Energy Construction

Littler on

On August 16, 2022, President Biden signed into law the Inflation Reduction Act (IRA) of 2022. Among many other provisions, the IRA contains a new federal 30% tax credit for private construction, alteration or repair of...more

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