News & Analysis as of

Tax Credits Comment Period

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Special Alert

State Agency Seeks Feedback on Targeted Georgia Tax Incentives - As the Georgia General Assembly works to assess the cost and effectiveness of the state's tax credits and exemptions, Georgia taxpayers have an opportunity...more

Cadwalader, Wickersham & Taft LLP

Everything You Need to Know About Energy Tax Credit Sales

The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits.  ...more

Holland & Knight LLP

Treasury Department, IRS Issue Additional Section 45V Clean Hydrogen PTC Guidance

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The U.S. Department of the Treasury Department and IRS on April 10, 2024, issued a supplemental notice of proposed rulemaking (NPRM) under the Internal Revenue Code's Section 45V clean hydrogen production tax credit (PTC)....more

Holland & Knight LLP

Inflation Reduction Act Direct Pay Rules Finalized

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The U.S. Department of the Treasury and IRS released final regulations under Section 6417 of the Internal Revenue Code, as enacted by the Inflation Reduction Act (IRA). Section 6417 allows certain taxpayers to elect to...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Schwabe, Williamson & Wyatt PC

Department of Treasury Issues Final Regulations Regarding Elective Pay Program ‎

The final regulations are effective on May 10, 2024. ‎ Last week, the Department of the Treasury issued final regulations that address the Elective Pay program (also called direct pay), predominantly under Internal Revenue...more

Holland & Knight LLP

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

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The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

Faegre Drinker Biddle & Reath LLP

Department of Treasury Issues Guidance on Section 45X Production Tax Credit

The U.S. Department of the Treasury, in conjunction with the Internal Revenue Service (IRS), released updated proposed guidance on the Section 45X Production Tax Credit (PTC). The guidance addresses specific requirements...more

McDermott Will & Emery

Weekly IRS Roundup December 11 – December 15, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 11, 2023 – December 15, 2023. ...more

A&O Shearman

Treasury’s Proposed Regulations on Energy Property and the Energy Investment Tax Credit

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Among other things, the proposed regulations would: Below is a more detailed summary of the key provisions in the proposed regulations as well as our initial observations. The IRS will collect comments until January 22, 2024,...more

Holland & Knight LLP

A Look at Foreign Entities of Concern and the Section 30D Clean Vehicle Tax Credit

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The U.S. Department of Energy (DOE) recently released proposed guidance defining "foreign entity of concern" (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Among other reasons, this proposed guidance is...more

Holland & Knight LLP

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

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The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more

Holland & Knight LLP

Section 48 Proposed Regulations Detail Treatment of Qualified Biogas Property

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The U.S. Department of the Treasury on Nov. 17, 2023, issued proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code (Code) that, following passage...more

Jones Day

Proposed IRS Regulations on Tax Credits for Renewable-Energy Investments Include Wage and Apprenticeship Requirements

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In Short - The Background: The Inflation Reduction Act provides for robust tax incentives on qualifying renewable-energy construction projects. In order to claim the full amount of such tax credits on qualifying projects,...more

Eversheds Sutherland (US) LLP

Rise and shine: IRS and Treasury provide insight on Notice 2023-63 and treatment of R&E expenditures under Section 174

At this morning’s Federal Bar Association breakfast briefing hosted by Eversheds Sutherland, officials from the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) discussed the recent substantive...more

Conyers

Government of Bermuda Consulting on Possible Introduction of Corporate Income Tax

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In response to the Pillar Two global minimum tax rules (the GloBE Rules) set out by the Organisation for Economic Co-operation and Development (OECD), the Government of Bermuda has issued a public consultation paper...more

Holland & Knight LLP

Treasury, IRS Issue Proposed Regulations on IRA Prevailing Wage and Apprenticeship Requirements

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Ten months after the release of initial guidance, the U.S. Department of the Treasury and IRS on Aug. 29, 2023, issued proposed regulations regarding increased credit or deduction amounts available for taxpayers satisfying...more

Eversheds Sutherland (US) LLP

Directions regarding Direct Pay - Proposed Regulations Released on Elective Payment for Inflation Reduction Act Renewable Energy...

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release much-anticipated guidance, including with respect to the monetization of energy tax credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a package of much-awaited guidance (the Guidance) consisting of (i) proposed regulations addressing the tax credit...more

Holland & Knight LLP

Treasury Department, IRS Release Low-Income Community Bonus Credit Proposed Rules

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The U.S. Department of the Treasury and IRS on May 31, 2023, released a Notice of Proposed Rulemaking (NPRM) regarding the low-income community bonus credit under Section 48 of the Internal Revenue Code. The NPRM requests...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

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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

Holland & Knight LLP

Eyes on Energy Tax Update: January 2023

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Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. The fourth quarter of 2022 brought a flurry of energy tax...more

Brownstein Hyatt Farber Schreck

IRS Solicits Public Comments on Additional Inflation Reduction Act Energy Tax Credits

Earlier today, Nov. 3, the IRS issued three new public notices concerning upcoming energy guidance on five of the tax incentives included in the recently passed Inflation Reduction Act (IRA). Each notice includes a brief...more

Wilson Sonsini Goodrich & Rosati

U.S. Treasury and the IRS Issue Request for Public Comments on Energy Tax Provisions in the Inflation Reduction Act

On October 5, 2022, the U.S. Treasury Department (the Treasury) and Internal Revenue Service (IRS) released six notices requesting public comment on the new and expanded energy tax provisions in the Inflation Reduction Act of...more

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