News & Analysis as of

Internal Revenue Service One Big Beautiful Bill Act Internal Revenue Code (IRC)

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.  
Eversheds Sutherland (US) LLP

Low Hanging Fruit: IRS Releases Rev. Proc. 2025-28 Providing Procedural Guidance for Domestic R&D Costs While Taxpayers Await...

On August 28, 2025, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc. 2025-28 providing procedural guidance for taxpayers seeking to take advantage of the One Big Beautiful Bill...more

Holland & Knight LLP

Beginning of Construction for Solar and Wind Facilities: What's Changed?

Holland & Knight LLP on

The IRS on Aug. 15, 2025, released Notice 2025-42, which provides guidance on how taxpayers can establish the "beginning of construction" (BOC) of a wind or solar facility for purposes of determining whether such facility is...more

Littler

Treasury Department Releases “Preliminary List” of “No Tax on Tips” Occupations

Littler on

The Treasury Department this week released a “preliminary list” of occupations that may be entitled to claim the “no tax on tips” deduction. As a reminder, the “One Big Beautiful Bill Act” (OBBBA) provides an above-the-line...more

Frost Brown Todd

Shifting Ground: How IRS Notice 2025-42 Redefines When Construction Begins for Applicable Wind and Solar Facilities

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On August 15, 2025, the Internal Revenue Service (IRS) released Notice 2025-42, consistent with President Trump’s recent Executive Order 14315 (EO 14315), which changes how applicable wind and solar facilities establish the...more

Hogan Lovells

U.S. Treasury releases New Beginning of Construction guidance on clean energy tax credits

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With an effective date of September 2, 2025, New Beginning of Construction guidance will be prospective and not apply to projects that satisfied beginning of construction under old IRS guidance before September 2, 2025. ...more

McDermott Will & Schulte

IRS roundup: August 12 – August 20, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 12, 2025 – August 20, 2025. August 15, 2025: The IRS issued Notice 2025-42, providing guidance consistent with...more

Whiteford

Client Alert: How the “One Big Beautiful Bill Act” Impacts Employers, Employees and Contractors

Whiteford on

The recently enacted One Big Beautiful Bill Act (the “Act”) introduces several significant amendments to the Internal Revenue Code (“IRC”) that directly affect U.S. employers and employees. Key provisions—particularly the...more

Holland & Hart LLP

Termination Effectiveness Beginning (Of Construction): Notice 2025-42

Holland & Hart LLP on

In response to Executive Order 14315 (July 7, 2025) (the “July 7 EO”), the IRS released Notice 2025-42 on August 15, 2025. Notice 2025-42 provides rules on how to begin construction for purposes of the effective dates of the...more

Pierce Atwood LLP

IRS Issues New Beginning of Construction Guidance for Solar and Wind Facilities

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On August 15, 2025, the Internal Revenue Service (IRS) issued Notice 2025-42 to address the beginning of construction (BOC) requirements for solar and wind projects under sections 45Y and 48E of the Internal Revenue Code...more

Haynes Boone

IRS Reminder: Educational Assistance Programs Can Help Pay Employee’s Student Loans

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The IRS recently issued a news release with a reminder that employers may contribute up to $5,250 annually per employee toward qualified student loan repayments if provided under a Section 127 educational assistance program....more

DLA Piper

IRS Releases Guidance on Wind and Solar Facility Tax Credits: Key Takeaways

DLA Piper on

The US Department of the Treasury and the Internal Revenue Service (IRS) recently released Notice 2025-42 to implement Executive Order (EO) 14315. The Notice, issued on August 15, 2025, provides guidance on when construction...more

Jones Day

New "Beginning of Construction" Guidelines Issued for Wind and Solar Tax Credits

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The Internal Revenue Service ("IRS") has issued Notice 2025-42 to implement the One Big Beautiful Bill Act ("OBBBA") mandate to phase out the clean electricity production tax credit (§ 45Y) and investment tax credit (§ 48E)...more

Troutman Pepper Locke

IRS Issues Beginning of Construction Guidance in Response to July Executive Order

Troutman Pepper Locke on

On August 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-42, which provides guidance on the beginning of construction requirement as it relates to the new credit termination...more

Baker Botts L.L.P.

Clean Energy Tax Credits: New Guidance on Beginning of Construction for Wind and Solar Facilities

Baker Botts L.L.P. on

On August 15, 2025, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released new guidance on the “beginning of construction” for wind and solar facilities under the clean electricity...more

Husch Blackwell LLP

Treasury Guidance Tightens "Beginning of Construction" Standards for Clean Energy Tax Credits, Eliminating 5% Safe Harbor for Wind...

Husch Blackwell LLP on

On August 15, 2025, the Internal Revenue Service (IRS) issued Notice 2025-42, providing long-awaited guidance on the “beginning of construction” requirements for wind and solar facilities under Sections 45Y and 48E of the...more

Holland & Knight LLP

IRS Releases New Beginning of Construction Rules for Clean Energy Tax Credits

Holland & Knight LLP on

The IRS on Aug. 15, 2025, released Notice 2025-42, which provides new guidance on how taxpayers can establish that they have begun construction of a wind or solar facility for purposes of determining whether such facility is...more

McGuireWoods LLP

IRS Notice 2025-42 Leaves Beginning of Construction Guidance for Wind and Solar Mostly Unchanged, But Limits 5% Safe Harbor to...

McGuireWoods LLP on

On Aug. 15, 2025, the U.S. Internal Revenue Service issued Notice 2025-42 addressing the beginning of construction for wind and solar facilities under Section 45Y and 48E of the Internal Revenue Code of 1986, as amended. The...more

Stoel Rives LLP

IRS Issues Guidance Regarding Beginning of Construction Requirement for PTC and ITC

Stoel Rives LLP on

The IRS today issued guidance regarding the “beginning of construction” requirement as it relates to the clean electricity production tax credit (PTC) under Internal Revenue Code Section 45Y and the clean electricity...more

Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

Frost Brown Todd on

Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part IX – Deductibility of Automobile Loan Interest

Foster Garvey PC on

In this ninth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that may permit individual taxpayers to deduct the interest incurred with respect to their...more

DLA Piper

Paying for Direct Primary Care Arrangements With HSAs is Now Permitted – With Caveats

DLA Piper on

While proposed frequently in Congress over the past few years, the One Big Beautiful Bill Act (OBBBA) has succeeded in revising the rules governing health savings accounts (HSA) in key ways that allow them to be used to pay...more

Fox Rothschild LLP

The One Big Beautiful Bill Act Changes Employee Retention Tax Credit Program

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While the One Big Beautiful Bill Act made headlines for tax and spending cuts, it also contains significant changes to the federal government’s treatment of COVID era Employee Retention Tax Credit (ERC) claims — many of which...more

Pullman & Comley, LLC

Overview of the Tax Provisions in the One Big Beautiful Bill Act

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On July 4, 2025,, the One Big Beautiful Bill Act (OBBBA) became law.  The Act itself was almost 1,000 pages.  It made many of the provisions of the 2017 Tax Cuts and Jobs Act permanent and included new federal tax provisions....more

Kelley Drye & Warren LLP

Employee Benefit Highlights of the ​“One Big Beautiful Bill Act”

Public Law 119-21, generally referred to as the ​“One Big Beautiful Bill” Act (the ​“Act”) and signed into law on July 4, 2025, includes several employee benefit provisions that employers will want to be aware of. Below is an...more

Jackson Walker

One Big Beautiful Bill Act Preserves Federal Tax Exemption for Municipal Bonds

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The One Big Beautiful Bill Act (the “OBBBA”) preserves the federal tax exemption for all municipal bonds, including both governmental purpose and qualified private activity bonds, which state and local governments rely on to...more

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