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Internal Revenue Service Regulatory Agenda 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.  
DLA Piper

Litigation Funding Tax and Retaliatory Tax: Top Points from the Latest JCT Scores

DLA Piper on

The Joint Committee on Taxation (JCT) on June 22, 2025, released tables providing revenue estimates for provisions of the recent Senate Committee on Finance bill language (JCX-29-25) as well as those of the comparable House...more

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

Williams Mullen on

On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Implications of Trump’s Recent Executive Actions

President Donald Trump has issued a series of executive orders with significant tax implications. The moves underscore the administration’s commitment to influencing tax policies, regulatory frameworks and trade practices as...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Cadwalader, Wickersham & Taft LLP

2024 Crypto Tax Year in Review

The crypto tax space saw significant developments in 2024. As 2025 ushers in new regulatory shifts (as our colleagues discussed here), tax changes may be on the horizon. In anticipation, this review revisits crypto tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax: Trump Exits Global Tax Deal and Freezes Green Energy Funds

Since assuming office on January 20, 2025, President Donald Trump has prioritized tax policy, issuing a series of directives aimed at boosting economic growth and advancing the “America First” agenda. On his first day in...more

Fenwick & West LLP

Senators Introduce Joint Resolution on Revoking DeFi Broker Reporting Regulations

Fenwick & West LLP on

On January 21, 2025, Senator Ted Cruz (R-TX), writing for himself and Senators Cynthia Lummis (R-WY), Bill Hagerty (R-TN), Thomas Tillis (R-NC), Tim Sheehy (R-MT), and Ted Budd (R-NC), introduced a joint resolution to the...more

Jones Day

Draft Guidance on the Section 45Z Clean Fuel Production Credit

Jones Day on

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

Baker Botts L.L.P.

Inflation Reduction Act Guidance: IRS and Treasury Release Final Regulations on the New Tech-Neutral Clean Energy Tax Credits

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On January 15, 2025, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) published final regulations regarding the new “clean electricity production credit” under Internal Revenue Code...more

Vinson & Elkins LLP

Treasury Releases Final Regulations for the Tech-Neutral PTC and ITC

Vinson & Elkins LLP on

On January 7, 2025, the U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 10024) (the “Final Regulations” and the preamble thereto, the...more

Farrell Fritz, P.C.

IRS Proposes Modernized Rules for Tax Professionals Under Circular 230

Farrell Fritz, P.C. on

Last month, the Department of the Treasury and the Internal Revenue Service (“IRS”) issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in...more

King & Spalding

Treasury and IRS Issue Final Regulations Implementing Section 45V Clean Hydrogen Production Tax Credit

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On January 3, 2025, the IRS and Treasury issued long-awaited final regulations (the “45V Final Regulations”) implementing the clean hydrogen production tax credit (the “45V Credit”) under Section 45V of the Internal Revenue...more

Baker Botts L.L.P.

Section 45V Tax Credit Implications for Nuclear & Clean Hydrogeny

Baker Botts L.L.P. on

The U.S. Department of the Treasury Department and Internal Revenue Service newly released Section 45V hydrogen tax credit guidance now includes nuclear plants if certain criteria are met - unlocking up to $3/kg for clean...more

A&O Shearman

Significant updates in Treasury's final energy credit regulations

A&O Shearman on

The U.S. Treasury Department and the Internal Revenue Service (“IRS”) published final regulations on December 4, 2024, defining “energy property” and rules applicable to energy credits (the investment tax credit, or the...more

Foley Hoag LLP - Energy & Climate Counsel

A Boon for Biogas: Treasury’s Final Section 48 ITC Rules Resolve Key Concerns for Biogas and RNG Projects

On December 4, 2024, the Department of the Treasury finalized new rules governing the Section 48 Investment Tax Credit (“ITC”). The ITC applies to a broad range of clean energy projects, including biogas projects, which were...more

McDermott Will & Schulte

IRS Issues Final Rules on Intangible Property Repatriations

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With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States is increasingly...more

McDermott Will & Schulte

Semiconductor Industry Receives Long-Awaited Tax Credit Guidance From Treasury

McDermott Will & Schulte on

On October 22, 2024, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited regulations implementing the advanced manufacturing investment credit under Sections 48D and 50...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

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

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Holland & Hart - Employers' Lawyers

IRS Issues Final Prevailing Wage and Apprenticeship Regulations

On June 25, 2024, the Internal Revenue Service and U.S. Department of Treasury published final Treasury Regulations (“Final Regulations”) in the Federal Register on the prevailing wage and registered apprenticeship...more

Bradley Arant Boult Cummings LLP

Inflation Reduction Act Prevailing Wage and Apprenticeship Compliance: Treasury and IRS Issue Final Rule

On June 18, 2024, Treasury and the IRS released the final rule for compliance with the prevailing wage and apprenticeship requirements (PWA requirements) pursuant to the Inflation Reduction Act of 2022 (IRA). This final rule...more

Ballard Spahr LLP

Treasury and IRS Propose Clean Electricity Investment Guidance

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The Treasury Department and IRS on Wednesday issued an eagerly awaited notice of proposed rulemaking to incentivize clean energy facilities: the “clean electricity production credit”—Section 45Y credit—and “clean electricity...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations on the Electric Vehicle Credits Under Section 30D of the Internal Revenue Code

The Final Regulations provide relief with respect to “impracticable-to-trace” battery materials. The new guidance provides additional detail for the transition rule applicable to qualified manufacturers, including as...more

Eversheds Sutherland (US) LLP

Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

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