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Prevailing Wage and Apprenticeship Requirements: Treasury Department and IRS Propose Regulations for Clean Energy Projects Under...

The Department of the Treasury and Internal Revenue Service (IRS) published proposed regulations (the “Proposed Regulations”) providing further guidance on the prevailing wage and apprenticeship requirements for clean energy...more

IRS Issues Direct Pay and Transferability Proposed Regulations

On June 14, 2023, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) under two novel provisions of the Inflation Reduction Act of 2022 (the “IRA”) designed to promote capital investment in renewable...more

The Inflation Reduction Act — Incentives for Clean Motor Vehicles and Refueling Property

The Inflation Reduction Act of 2022 (the “IRA”) released by U.S. Senate Democrats on July 27, 2022 would, if enacted, provide a number of financial incentives to encourage the purchase of electric and hydrogen fuel cell...more

Proof-of-Stake Rewards: Payment for Services or a Baked Cake?

Against the backdrop of rapidly evolving blockchain technology, the IRS has oftentimes been slow to update its related tax guidance, leaving participants in the blockchain ecosystem uncertain about their tax obligations....more

Infrastructure Law Adds Important Crypto Provisions

The Infrastructure Investment and Jobs Act, enacted on November 15, 2021, also known as the Bipartisan Infrastructure Law (the “BIL”), adds many important provisions regarding the development of the United States’...more

IRS Finalizes Guidance Relating to Carbon Capture and Sequestration

On January 6, 2021, the IRS issued final regulations relating to section 45Q. This is the fourth piece of guidance from the IRS relating to section 45Q, following IRS Notice 2020-12, Revenue Procedure 2020-12, the Proposed...more

Word on the Street Is That Virtual Currency Is the “New Gold,” and it’s Swiftly Moving Up the IRS Watchlist

The IRS has been increasingly active in its effort to ensure that virtual currency does not become a tool for tax evasion. This is not surprising, given that—as we started the last month of 2020—the value of Bitcoin, by far...more

Financial Incentives for Carbon Capture, Use and Sequestration

Background. - While the fossil fuel industry continues to enjoy a number of tax incentives, a new generation of tax incentives were enacted in the early 2000s to promote the use of renewable energy. These include the...more

Department of Energy and USEA Release Comprehensive Carbon Capture Incentives Report Co-authored by Orrick

On September 21, the United States Energy Association (“USEA”), on behalf of the Department of Energy Office of Fossil Energy, released a comprehensive report on the current state of carbon capture, utilization, and...more

Final Tax Regulations Offer More Certainty to Opportunity Zone Fund Managers and Investors

Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more

HMRC’s New Approach to Cryptoassets – Tax First, Define Later

The UK tax authority, Her Majesty’s Revenue & Customs (HMRC), has taken a further step towards tackling perceived tax avoidance in transactions involving cryptoassets. Specifically, according to press reports, exchanges such...more

Carbon Capture Sequestration – Orrick Responds to the IRS Request for Comments

On May 2, 2019, the Internal Revenue Service ( the “IRS”) released Notice 2019-32 (the “Notice”) which requested comments for Carbon Oxide Sequestration Section 45Q of the Internal Revenue Code....more

Carbon Capture and Sequestration: Incentives Update

Section 45Q Tax Credits Internal Revenue Code Section 45Q provides a tax credit for the sequestration or use of qualified carbon oxides (“COx”), including CO2. Although Section 45Q was enacted in 2008, there was uncertainty...more

IRS Reports Record $312 Million In Whistleblower Bounties

In February, the Internal Revenue Service (IRS) released its FY 2018 Annual Report and announced a record-breaking year for the agency’s whistleblower program. Overall, whistleblowers provided information that contributed to...more

IRS Outlines New Process for Voluntary Disclosures

On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more

IRS Extends Date for Section 965 Liability Transfer Agreement

Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more

Ninth Circuit Upholds Validity of Cost-Sharing Regulations that Stray from Arm's-Length Standard

On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

IRS Releases Transition Guidance for the Dividend Equivalent Rules

On December 2, 2016, the Internal Revenue Service (the “IRS”) issued Notice 2016-76 (the “Notice”), which provides highly anticipated guidance regarding “dividend equivalent” payments under section 871(m) of the Internal...more

IRS and Treasury Issue Final Regulations Under §385 Classifying Interests in a Corporation

On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

Derivatives in Review - July 2016

An Overview of Proposed Regulation AT - Orrick attorneys authored an overview of Regulation Automated Trading (known as "Regulation AT") proposed by the Commodity Futures Trading Commission ("CFTC") in the May/June 2016...more

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

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