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Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Energy Credit Transferability Regulations Finalized

On April 25, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for...more

Final Direct Pay Regulations Released

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

Treasury Issues Proposed Regulations on 45X Advanced Manufacturing Production Credit

On December 14, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) providing additional guidance to taxpayers on the advanced...more

Treasury Releases a Swath of Guidance on the Investment Tax Credit

On November 17, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations [REG-132569-17] regarding the definition of “energy property” and related rules...more

Treasury Issues Proposed Regulations for IRA Labor Requirements

On August 29, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) providing proposed rules governing the prevailing wage and...more

Full Speed Ahead: The Inflation Reduction Act at One Year

It’s the largest climate legislation in US history, with many complex provisions. But let’s start with the big picture: A year on from the Inflation Reduction Act becoming law, is it living up to its promise?...more

Energy Community Guidance Updated for Unemployment Data

Taxpayers have anxiously been awaiting clarity on energy community status based on the 2022 unemployment rates to establish location in an energy community through metropolitan statistical area (“MSA”) or non-metropolitan...more

Guidance Clears the Way for Direct Pay – Treasury Releases Preliminary “Elective Payment” Regulations

On June 14, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations and temporary regulations regarding the direct pay election1 for certain tax credits...more

Transfer Away! Treasury Releases Preliminary Ground Rules for Tax Credit Transfers

On June 14, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed and temporary regulations regarding the transfer elections for certain tax credits available...more

Treasury Issues Initial IRA Labor Guidance

In a surprising release, on November 29, 2022, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued Notice 2022-61 (the “Notice”) providing initial guidance on the prevailing...more

[Webinar] The Inflation Reduction Act: What Do Wages and Apprentices Have to Do with Taxes? - November 9th, 12:00 pm - 1:00 pm CT

Attorneys from our Employment, Labor and OSHA (ELO) and Tax Groups will discuss the prevailing wage and apprenticeship requirements in the Inflation Reduction Act. Topics will include the requirements necessary to obtain tax...more

New Climate Law Overhauls US Tax Code With Benefits, Flexibility

The Inflation Reduction Act of 2022 (IRA) represents one of the most sweeping pieces of climate policy legislation ever enacted in the United States. While the final impact of the IRA remains to be seen, we expect there will...more

House Passes Historic Inflation Reduction Act!

On August 12, 2022 – a little over two weeks after the legislation was announced and five days after it passed the Senate – the House passed the historic Inflation Reduction Act of 2022 (the “Act”). While the legislation...more

[Webinar] Renewable Reboot: A Download on the Inflation Reduction Act of 2022 – Clean Energy Tax Provisions - August 4th, 3:00 pm...

On July 27, 2022, Senators Manchin (D-WV) and Schumer (D-NY) debuted the Inflation Reduction Act of 2022, a piece of legislation that, if enacted, would be a historic investment in climate policy as well as a down payment on...more

Renewable Reboot – The Inflation Reduction Act of 2022 Released as Senator Joe Manchin (D-WV) Changes Stance on Climate Change and...

On July 27, 2022, only a few hours after the Senate approved a bipartisan semiconductor and technology package, Senator Manchin made a stunning and well-timed reversal of his prior position and confirmed his support for...more

Senate Finance Committee Modifies Clean Energy Tax Proposals in Build Back Better Reconciliation Bill

Early on December 11, 2021, the Senate Finance Committee released its version of the Build Back Better Act (the “Act”). While the Senate Finance Committee version of the Act largely replicates the clean energy proposals...more

House Passes Build Back Better Reconciliation Bill

Early on November 19, 2021, the House passed H.R. 5376, the Build Back Better Act (the “Act”) along partisan lines. Passage came after the Congressional Budget Office released projections on the overall net cost of the...more

Clean Energy Tax Proposals in Biden’s New “Build Back Better” Framework

Faced with opposition from within his own party, President Biden last week unveiled a new, pared down framework for his “Build Back Better” agenda. Following release of the president’s framework, H.R. 5376 (the “Build Back...more

What’s Driving Transition Energy IPOs and SPAC Combinations?

I. Introduction - This research updates last year’s report entitled, “Clean Energy IPOs and SPAC Combinations” published in August of 2020. While investments in “energy transition,” “clean energy” or with an “ESG focus”...more

Offshore Wind — The Current State of Affairs

I. Introduction - Renewable energy development and the “energy evolution” continue to make a splash in energy infrastructure, legislation, and investment. And, among renewable energy technologies, offshore wind may be set...more

New IRS Guidance On Carbon Capture Projects Answers Some Questions, Raises Others

The IRS published Revenue Ruling 2021-13 on July 1, 2021, addressing a series of issues on the Section 45Q tax credit for carbon capture projects. Specifically, the Revenue Ruling focuses on a methanol plant and tackles...more

IRS Extends Continuity Safe Harbor For Renewable Energy Projects

On June 29, 2021, the Internal Revenue Service (“IRS”) issued IRS Notice 2021-41 (the “Notice”), which extends the “Continuity Safe Harbor” for renewable energy projects that qualify for production tax credits under Section...more

Will Direct Pay Change The Renewable Energy Investment Landscape?

Key Takeaways: •In an effort to spur investment in renewable energy projects, Congress and the Biden Administration are considering “direct pay” options- •Direct pay would allow project developers to receive tax...more

Final Carbon Capture Regulations Should Spur Investment

Yesterday, Treasury and the IRS issued final regulations on the expanded carbon capture tax credit implementing a number of welcome changes and clarifications to the proposed regulations. Key changes are generally...more

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