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McDermott Will & Emery

IRS roundup: June 18 – July 11, 2025

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025. “One Big Beautiful Bill Act” tax provisions - On July 4, 2025, US President Donald...more

McDermott Will & Emery

IRS Roundup February 17 – March 14, 2025

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Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

McDermott Will & Emery

FedEx Defeats Government’s Loper Bright Gambit

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On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more

Orrick, Herrington & Sutcliffe LLP

Final Regulations Released for the Clean Electricity Low-Income Communities Bonus Credit Program

The U.S. Department of the Treasury and the Internal Revenue Service have published final regulations concerning the low-income communities bonus credit program under Section 48E(h) of the Internal Revenue Code of 1986, as...more

Orrick, Herrington & Sutcliffe LLP

New IRS Guidance on Domestic Content Bonus Credit

The U.S. Department of the Treasury and the Internal Revenue Service have issued Notice 2025-08 (the “First Updated Elective Safe Harbor”), offering new guidance on the bonus credit for projects using domestically produced...more

Mayer Brown

Treasury Issues Final Regulations on Technology Neutral Clean Energy Projects

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On January 7, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) relating to technology-neutral tax credits for clean energy...more

Holland & Knight LLP

Key Highlights of the Section 761 Final Regulations and Impact on Section 6417 Direct Payments

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Under Section 6417 of the Code, as enacted by the Inflation Reduction Act (IRA), certain taxpayers that fall within the statutory definition of "applicable entities" are allowed to elect to receive a direct payment (i.e.,...more

Latham & Watkins LLP

IRS Finalizes Hydrogen Tax Credit Regulations

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The final regulations adopt the general framework established in the proposed regulations issued in December 2023, but with several significant modifications....more

Mayer Brown

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

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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

McDermott Will & Emery

Semiconductor Industry Receives Long-Awaited Tax Credit Guidance From Treasury

McDermott Will & Emery 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

Fleurinord Law PLLC

The Pros and Cons of Parents Claiming College Students as Dependents

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As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more

Pierce Atwood LLP

Energy Tax Credits – Final Regulations on Transferability and Guidance on Domestic Content

Pierce Atwood LLP on

The Treasury Department and IRS recently issued final regulations on the transfer of certain credits to implement the transferability provisions of the Inflation Reduction Act (IRA), which take effect on July 1, 2024....more

Eversheds Sutherland (US) LLP

Energy tax credit transfers: Treasury and IRS issue final regulations on the section 6418 transferability rules

[unable to retrieve full-text content]On April 25, 2024, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations on the transferability of certain tax credits under the...more

Schwabe, Williamson & Wyatt PC

Department of Treasury Issues Final Regulations Regarding Elective Pay Program ‎

The final regulations are effective on May 10, 2024. ‎ Last week, the Department of the Treasury issued final regulations that address the Elective Pay program (also called direct pay), predominantly under Internal Revenue...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

Troutman Pepper Locke

IRS Issues Proposed Regulations on Energy Property and Rules Applicable to Energy Credit Under Section 48

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The IRS and the Treasury Department issued proposed regulations under Section 48 on November 22, 2023 (Proposed Regulations), providing further guidance in determining whether property is energy property and eligible for the...more

Eversheds Sutherland (US) LLP

An apparent 180 degree turn by the Service with research credit claims

On January 3, 2022, the IRS Office of Chief Counsel released an interim guidance memorandum (the Interim Guidance), along with a set of FAQs, to provide IRS Examining Agents with procedural guidance for applying Field...more

Mintz - ML Strategies

What You Need to Know: State and Federal Updates Related to COVID-19

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...On Monday, House Speaker Nancy Pelosi, Majority Whip James Clyburn, Transportation & Infrastructure Committee Chairman Peter DeFazio, and Energy & Commerce Committee Chairman Frank Pallone held a press conference on a...more

Eversheds Sutherland (US) LLP

Ready, set, sequester? - A guide to the recently released section 45Q guidance

On February 19, 2020, the Internal Revenue Service (IRS) issued two highly anticipated items of guidance under section 45Q, which provides a tax credit for carbon capture and sequestration (CCS) projects. IRS Notice 2020-12...more

Mayer Brown

Final Regulations Published Addressing Income Inclusion Rules for Pass-Through Lease of ITC Property

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On July 17, 2019, the US Internal Revenue Service (IRS) issued final regulations (T.D. 9872) providing guidance on the rules under Internal Revenue Code (IRC) section 50(d)(5) requiring an income inclusion by the lessee in...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Issue No. 2 | 2018 - A summary of state and federal developments in the captive insurance industry

Vermont's Leadership Team - Vermont’s leadership team largely stayed the course in 2017. Governor Phil Scott and Michael Pieciak, the Commissioner of the Department of Financial Regulation (the “DFR”), each completed a...more

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