News & Analysis as of

U.S. Treasury Foreign Entities Tax Planning

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

Morrison & Foerster LLP

Treasury Department Shifts CTA to Foreign Entities

As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to 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

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