As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more
The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more
The IRS and Treasury on June 3 issued proposed regulations under Sections 45Y and 48E (proposed regulations), which address clean electricity production and investment tax credits, respectively, that generally replace...more
On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more
3/13/2024
/ Energy Projects ,
Grants ,
IRS ,
Loans ,
New Regulations ,
Partnerships ,
Production Tax Credit ,
Registration Requirement ,
Renewable Energy ,
S-Corporation ,
Tax Credits ,
Tax Exempt Entities ,
Tax Returns ,
U.S. Treasury
As covered in our prior alerts, the Inflation Reduction Act enacted new renewable energy credits, including an advanced manufacturing production credit under Section 45X that provides tax credits to domestic producers and...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
9/18/2023
/ Apprenticeships ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Penalties ,
Prevailing Wages ,
Production Tax Credit ,
Recordkeeping Requirements ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act[1] (IRA) modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable...more
As covered in our prior alert, the Inflation Reduction Act[2] (IRA) modified and reinstated existing renewable energy credits and enacted new renewable energy credits. The IRA also enacted two novel alternatives to tax equity...more
On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more
Key Takeaways:
..Recently enacted direct pay and transfer provisions apply to certain clean energy tax credits. These provisions will have a significant impact on how taxpayers can monetize these tax credits and, in...more
9/16/2022
/ Biden Administration ,
Carbon Capture and Sequestration ,
Clean Energy ,
Climate Change ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
Monetization ,
Production Tax Credit ,
Renewable Energy ,
Tax Credits
Key Takeaways:
..The Senate voted 51-50 on August 7 to pass the Inflation Reduction Act.
..The legislation is expected to pass the House this week without changes and to be signed by President Biden.
..The...more
8/8/2022
/ Climate Change ,
Corporate Taxes ,
Drug Pricing ,
Energy Projects ,
Federal Funding ,
Inflation Adjustments ,
Medicare ,
Oil & Gas ,
Pending Legislation ,
Prescription Drugs ,
Renewable Energy ,
Superfund ,
Tax Credits
Key Takeaways:
..The law regarding computation of FBAR penalties is unclear.
..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts.
..Until the Supreme Court...more
The House Ways and Means Committee this week released draft legislation advancing various tax change proposals. The House action follows several recent releases by the Senate Finance Committee, including proposals focused on...more
The White House and Treasury today released the Fiscal Year 2022 Federal Budget and the Treasury Green Book, which include new details regarding the Biden administration’s American Families Plan and proposed 2021 tax changes...more
The White House today released The American Families Plan, which includes some new details regarding the Biden administration’s proposed 2021 tax reform. The tax changes expected to be enacted this year will be substantial...more
With release by the White House and Treasury of initial details regarding Biden Administration proposed 2021 tax reform, a primary focus in Washington, D.C., for the next seven months or so will be expected changes to the tax...more
With the passage of the Biden Administration’s COVID-19 relief bill, the focus in Washington, D.C., has shifted to Administration plans for investment in infrastructure and related items and significant tax changes to help...more
President Biden signed the American Rescue Plan Act of 2021 (ARPA), an approximately $1.9 trillion COVID-19 relief, funding and tax bill that includes $1,400 direct payments to individuals, an extension of the $300 federal...more
3/12/2021
/ American Rescue Plan Act of 2021 ,
Biden Administration ,
Child Tax Credit ,
Corporate Taxes ,
Earned Income Credit ,
Employee Retention ,
Families First Coronavirus Response Act (FFCRA) ,
Financial Stimulus ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
Tax Credits
With expected passage in the next few weeks of the Biden Administration’s first COVID-19 relief bill, the focus in Washington, D.C., will shift to a second budget reconciliation bill – Biden Administration tax changes. The...more
On Dec. 21, 2020, Congress passed the Consolidated Appropriations Act, 2021 (CAA), an approximately $2.3 trillion omnibus appropriations bill to fund the government through September of 2021 that includes $900 billion of...more
In the past several years, the use and prevalence of virtual currency have increased exponentially. The proliferation of digital assets has changed the way goods and services are exchanged and has allowed for faster and...more