News & Analysis as of

U.S. Treasury Internal Revenue Service Tax Incentives

Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

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One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Snell & Wilmer

A New Chapter for Clean Energy: Final ITC Regulations Unveiled

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On December 4, 2024, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (T.D. 10015) related to the energy credit under Section 48 of the Internal Revenue Code. These...more

McDermott Will & Schulte

IRS Issues Final Rules on Intangible Property Repatriations

McDermott Will & Schulte on

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

Flaster Greenberg PC

Airport Electrification – Latest IRS Guidance

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The Department of the Treasury and Internal Revenue Service continue to issue guidance regarding the Inflation Reduction Act of 2022 (IRA), which modified and extended the clean energy investment tax credit (ITC) under...more

Amundsen Davis LLC

Tax Incentives for Green Energy Projects Come With a Lot of Strings Attached

Amundsen Davis LLC on

On August 29, 2023, Clock on Grassthe U.S. Department of the Treasury and the Internal Revenue Service (IRS) released more guidance and proposed rules on key provisions in the Inflation Reduction Act (IRA) that requires...more

Pillsbury Winthrop Shaw Pittman LLP

Estate and Tax Planning 2023 Update: Act While You Can

Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more

Bradley Arant Boult Cummings LLP

Treasury and IRS propose renewable energy prevailing wage and apprenticeship requirements

Payment of a prevailing wage to workers and employment of apprentices are key requirements for renewable energy developers to obtain the various tax incentives for their projects provided by the Inflation Reduction Act of...more

Foley & Lardner LLP

Opportunity Zones: Should Your Startup Make One Its Home?

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A Qualified Opportunity Zone (QOZ) is an economically distressed community where new investments, under certain conditions, may be eligible for preferential tax treatment. The U.S. federal government created this tax...more

Wiley Rein LLP

Treasury Department Issues Guidance and Timeline to Allocate $4 Billion in Qualifying Advanced Energy Project Credits

Wiley Rein LLP on

On May 31, 2023, the U.S. Department of the Treasury's Internal Revenue Service (IRS) released additional guidance on the implementation and administration of Internal Revenue Code §48C—The Qualifying Advanced Energy Project...more

Husch Blackwell LLP

IRS Releases Guidance on Domestic Content Bonus Credit Amounts

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On May 12, 2023, in Notice 2023-38 (the “Notice”), the IRS published rules intended for inclusion in forthcoming regulations regarding domestic content bonus credit amounts. The Inflation Reduction Act of 2022 amended §§...more

Allen Matkins

Renewable Energy Update - 5.18.23

Allen Matkins on

Demand for energy is expected to soar by mid-century as the state attempts to electrify everything from transportation to home-heating systems. To help get there, the California Independent System Operator recently proposed...more

Wiley Rein LLP

Treasury and IRS Provide Initial Guidance on Inflation Reduction Act Domestic Content Bonus Credit Requirements

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On May 12, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued initial guidance on the Inflation Reduction Act’s (IRA) requirements for domestic content bonus tax credits for...more

Holland & Knight LLP

Treasury Department, IRS Release Clean Vehicle Tax Guidance

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The U.S. Department of the Treasury and IRS have released several pieces of guidance regarding the tax incentives for clean vehicles provided under Sections 30D (new clean vehicle credit), 25E (previously owned vehicle...more

Holland & Knight LLP

Treasury Department Issues Section 48D Guidance on CHIPS Act Semiconductor Tax Incentive

Holland & Knight LLP on

The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more

Morgan Lewis

IRS and DOE Publish Details on First Allocation of $10B Section 48C Green Technology Industry Tax Credits Authorized by IRA

Morgan Lewis on

he Internal Revenue Service (IRS), the Treasury Department (Treasury), and the Department of Energy (DOE) released Notice 2023-18 (Notice) on February 13, detailing the procedures through which the IRS and DOE will award a...more

Stoel Rives LLP

Treasury Issues Guidance on Section 48C Credit Allocation Program

Stoel Rives LLP on

On February 13, 2023, the U.S. Department of the Treasury released Internal Revenue Service (IRS) Notice 2023-18, Initial Guidance Establishing Qualifying Advanced Energy Project Credit Allocation Program Under Internal...more

Bradley Arant Boult Cummings LLP

The clock is ticking on the IRA’s prevailing wage and apprenticeship requirements

Renewable energy developers and contractors have been anticipating the Treasury Department and IRS’s initial guidance on what is required to satisfy the prevailing wage and apprentice requirements under the Inflation...more

Mintz - Energy & Sustainability Viewpoints

Last Call: Public Comments on Inflation Reduction Act Clean Energy Tax Incentives Are Requested By November 4

On October, 5, 2022, the U.S. Department of Treasury (Treasury) and Internal Revenue Service (IRS) published six Notices requesting public comments by November 4, 2022 on certain of the clean energy tax incentives included in...more

Mintz - ML Strategies

Energy & Sustainability Washington Update — November 2022

Mintz - ML Strategies on

Congress was in recess for the month of October for the final push toward the November 8 midterm elections, but executive branch activities related to energy and sustainability have continued. Treasury & IRS Seek Public...more

McDermott Will & Schulte

Key International Tax Proposals in the Biden Administration’s Green Book and Their Potential Impact on Businesses

On May 28, 2021, the US Department of the Treasury (Treasury) released the Fiscal Year (FY) 2022 budget and Green Book, which provides detailed insights into the proposals of US President Joe Biden’s recently released...more

Farella Braun + Martel LLP

Legal Ins and Outs of ‘Opportunity Zones’ — so Far

A new tax incentive intended to stimulate investment in low-income communities known as opportunity zones has attracted significant attention from investors, developers, and business owners since its enactment under Section...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more

Jackson Walker

Treasury Releases Additional Qualified Opportunity Zone Guidance

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On April 17, the Treasury Department released a second round of guidance, bringing additional clarity to the Qualified Opportunity Fund (or QOF) regime enacted by 2017’s Tax Cuts and Jobs Act. Some important questions remain...more

Foster Garvey PC

Opportunity Zone Funds – Part I: Overview of the Law

Foster Garvey PC on

BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Guidance for Opportunity Zone Funds Clarifies Important Issues, Leaves Door Open to Additional Guidance

The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more

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