News & Analysis as of

Proposed Regulation Internal Revenue Code (IRC) Tax Credits

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

McCarter & English, LLP

Proposed Corporation Business Tax Regulations, Proposing Sweeping Changes, Published in ‘New Jersey Register’

On February 18, the New Jersey Division of Taxation published proposed corporation business tax (CBT) regulations that incorporate changes associated with 2023 reform legislation, as well as additional changes intended to...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

Jones Day on

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

A&O Shearman

Proposed regulations provide guidance regarding certain aspects of spinoffs and reorganizations

A&O Shearman on

On January 13, 2025, the U.S. Treasury Department (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (REG-112261-23 and REG-112261-24) adding and amending parts of the regulations...more

Pillsbury Winthrop Shaw Pittman LLP

Initial Guidance on Clean Fuel Production Credit Under IRC Section 45Z

On January 10, 2025, the Internal Revenue Service (IRS) issued Notice 2025-10 and Notice 2025-11. Notice 2025-10 summarizes proposed regulations (Proposed Regulations) that Treasury and the IRS plan to issue with respect to...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

Mayer Brown on

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

Paul Hastings LLP

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

Paul Hastings LLP on

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

Holland & Knight LLP

Treasury Department, IRS Release Section 30C Proposed Regulations

Holland & Knight LLP on

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

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

Jones Day

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

Jones Day on

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

McNees Wallace & Nurick LLC

U.S. Treasury Proposes New Regulations on Eligibility Requirements for Clean Energy Tax Credits under the Inflation Reduction Act

The United States Department of the Treasury (Treasury) on June 3, 2024 published proposed regulations on Internal Revenue Code (IRC) Sections 45Y and 48E, which provide for clean energy production and investment tax credits...more

Vinson & Elkins LLP

Treasury Releases Proposed Regulations on Tech-Neutral PTC and ITC

Vinson & Elkins LLP on

On May 29, 2024, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations (REG-119283-23) (the “proposed regulations”) regarding the clean electricity production...more

Bracewell LLP

Treasury Department and IRS Release Proposed Regulations for Clean Electricity Credits Under Code Sections 45Y and 48E

Bracewell LLP on

On May 29, 2024, the Treasury Department and the Internal Revenue Service (IRS) released a notice of proposed rulemaking (Proposed Regulations) with respect to Section 45Y (clean electricity production credit or CEPC) and...more

McDermott Will & Emery

Weekly IRS Roundup May 20 – May 24, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. ...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Propose Supplemental Notice Regarding Clean Hydrogen Production Tax Credit Regulations

On April 10, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of proposed rulemaking (the Supplemental Regulations) to supplement the Clean Hydrogen Production Tax...more

McDermott Will & Emery

Weekly IRS Roundup April 1 – April 5, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1, 2024 – April 5, 2024....more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed and Final Regulations on Direct Pay Elections

On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more

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

Long Awaited Elective Payment Election Final Regulations and Other Guidance Issued by Treasury Department and IRS

On March 5, 2024, the U.S. Department of Treasury and Internal Revenue Services (IRS) released final regulations regarding the direct payment election under the Inflation Reduction Act of 2022 (IRA), a tax credit monetization...more

Vinson & Elkins LLP

Final Direct Pay Regulations Released

Vinson & Elkins LLP on

On March 5, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Final Direct Pay Regulations”) regarding the direct pay election for certain tax...more

Holland & Knight LLP

Treasury Department, IRS Correct Section 48 Proposed Regulations on Qualified Biogas Property

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The U.S. Department of the Treasury and IRS on Feb. 16, 2024, released a correction to Internal Revenue Code Section 48 Proposed Regulations relating to the new investment tax credit (ITC) for biogas. The correction provides...more

Holland & Hart LLP

Fund Formation and Credit Transfers: Monetizing Tax Credits Using Partnerships

Holland & Hart LLP on

Section 6418 of the Internal Revenue Code (as added by the Inflation Reduction Act of 2022) allows an eligible taxpayer that qualifies for certain clean energy tax credits, including investment tax credits and production tax...more

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