News & Analysis as of

Internal Revenue Service Foreign Entities U.S. Treasury

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Husch Blackwell LLP

New Executive Order Targets Wind and Solar Tax Credits

Husch Blackwell LLP on

On July 7, 2025, President Trump signed the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources.” The EO directs the Secretary of the Treasury to “strictly enforce” the...more

Baker Botts L.L.P.

The "One Big Beautiful Bill Act" Substantially Alters Clean Energy Tax Landscape

Baker Botts L.L.P. on

On July 4, 2025, the legislation commonly known as the "One Big Beautiful Bill Act" (the “BBBA”) was enacted. The BBBA makes significant changes to the tax credits available under the Inflation Reduction Act of 2022 (the...more

McDermott Will & Emery

Proposed Disregarded Payment Loss Rules Create Traps for the Unwary

McDermott Will & Emery on

Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s coming. Under the...more

Mayer Brown

Final Guidance Issued on “Foreign Entity of Concern” Criteria

Mayer Brown on

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

Holland & Knight LLP

Treasury Department, IRS Issue Final Rules Under Clean Vehicle Tax Credits

Holland & Knight LLP on

The Federal Register on May 6, 2024, published final regulations issued by the U.S. Department of the Treasury and IRS under the clean vehicle tax credits found at Sections 25E (previously owned clean vehicles) and 30D (clean...more

Miller Canfield

US Issues Final Regulations on FEOC Exclusions from Clean Vehicle Credit

Miller Canfield on

On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more

Jones Day

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

Jones Day on

The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Paul Hastings LLP

Treasury Issues Proposed Regulations on the Section 30D Clean Vehicle Tax Credit’s Foreign Entity of Concern Rules

Paul Hastings LLP on

The Inflation Reduction Act of 2022 brought about modifications to the clean vehicle tax credit available under Section 30D of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Clean Vehicle...more

Eversheds Sutherland (US) LLP

DOE, Treasury and IRS issue guidance regarding foreign entity of concern for section 30D tax credit eligibility

On December 4, 2023, the Department of Energy (DOE), Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published related proposed guidance on the eligibility of an electric vehicle for the section...more

Jones Day

Proposed Guidance Clarifies "Foreign Entity of Concern" Restrictions for Clean Vehicle Credit

Jones Day on

New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...more

Miller Canfield

US Issues Proposed Regulations on FEOC Exclusions from Clean Vehicle Credit

Miller Canfield on

On December 4, 2023, the U.S. Department of the Treasury and Internal Revenue Service (IRS) published long-awaited proposed regulations (Notice of Proposed Rulemaking) regarding the Foreign Entity of Concern (FEOC) exclusions...more

Troutman Pepper Locke

Guidance Suggests U.S. Clean Vehicle Subsidies Require Disengagement From China Supply Chains

Troutman Pepper Locke on

On December 1, the U.S. Department of Energy (DOE) released long-awaited proposed guidance defining “foreign entity of concern” (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Simultaneously, the U.S....more

Akin Gump Strauss Hauer & Feld LLP

Clean Vehicle Tax Credit – Foreign Entity of Concern Rules Proposed

On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more

Holland & Knight LLP

A Look at Foreign Entities of Concern and the Section 30D Clean Vehicle Tax Credit

Holland & Knight LLP on

The U.S. Department of Energy (DOE) recently released proposed guidance defining "foreign entity of concern" (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Among other reasons, this proposed guidance is...more

Holland & Knight LLP

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Proskauer - Tax Talks

IRS Proposed Regulations Under Section 305(c)

Proskauer - Tax Talks on

In April, the IRS issued proposed regulations interpreting deemed distributions under Section 305(c). Specifically, the proposed regulations would clarify the amount and timing of deemed distributions that result from an...more

Farella Braun + Martel LLP

Final Regulations Provide Guidance for Private Foundations Making Foreign Grants

When making grants to foreign organizations, private foundations must conduct costly and time-consuming expenditure responsibility, unless the foundation makes a good faith determination that the foreign organization is...more

Morgan Lewis

Treasury and IRS Release Notice 2015-54: Potential Impact on Domestic and Foreign Partnerships

Morgan Lewis on

The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event. On August 6, the US Treasury...more

19 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide