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Transfer Pricing and Tariffs: Finding Certainty in Trade Uncertainty

The current administration’s whipsaw of imposed and withdrawn tariffs continues to rattle financial markets and industries across the United States. In New England, annual trade of goods and services with Canada exceeds...more

Final Regulations on Partnership Recourse Liability Allocation and Related-Party Rules

Recently, the Treasury Department and IRS released final regulations (89 Fed. Reg. 231) on the allocation of partnership recourse liabilities and related-party rules under Section 752 (the Final Regulations). The Final...more

New Guidance for Clean Electricity Low-Income Communities Bonus Program

The U.S. Department of the Treasury recently issued proposed regulations to implement the Clean Electricity Low-Income Communities Bonus Program, which was created under the Inflation Reduction Act to incentivize clean energy...more

Will Treasury Use Energy Tax Credits to Assist PFAS-Impacted Communities?

Proposed tax regulations to be released this year may clarify whether agricultural land contaminated with per- and polyfluoroalkyl substances (PFAS) qualify for a federal tax credit that would incentivize renewable energy...more

Energy Tax Credits – Final Regulations on Transferability and Guidance on Domestic Content

The Treasury Department and IRS recently issued final regulations on the transfer of certain credits to implement the transferability provisions of the Inflation Reduction Act (IRA), which take effect on July 1, 2024....more

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