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House Reconciliation Bill Amends Clean Energy Provisions of the IRA

On May 22, 2025, the House of Representatives passed its reconciliation bill, H.R. 1, entitled “One Big Beautiful Bill Act” (the “legislation”), which significantly amends the clean energy provisions that were enacted as part...more

Treasury Issues Final Regulations on Technology Neutral Clean Energy Projects

On January 7, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) relating to technology-neutral tax credits for clean energy...more

IRS Releases Final Energy Property Regulations Under Section 48 Investment Tax Credit

On December 4, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations, TD 10015, (the “Final Regulations”), which provide guidance on the definition of energy...more

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) to allow certain unincorporated organizations owned by specified “applicable...more

Treasury and IRS Issue Final Regulations on Section 45X

On October 24, 2024, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) on the Section 45X Advanced Manufacturing Production Credit of the...more

Outlook for Energy and Tax Policy in 2025

While we await the outcome of the upcoming US elections, stakeholders in the energy tax and policy space should recognize that, regardless of the outcome of the election, there will be plenty of activity in the energy sector...more

Final Regulations Issued on Prevailing Wage and Apprenticeship Requirements under the Inflation Reduction Act

On June 18, 2024, the US Internal Revenue Service (“IRS”) and Department of the Treasury (“Treasury”) issued final regulations (“Final Regulations”) establishing rules for taxpayers intending to satisfy the prevailing wage...more

Final Guidance Issued on “Foreign Entity of Concern” Criteria

On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

Final Regulations Issued on Direct-Pay Elections and Transfer of Tax Credits

On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations under section 6418”) concerning the election to transfer...more

Proposed Regulations on Section 45X Advanced Manufacturing Production Tax Credit

On December 14, 2023, the Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed regulations to implement the Section 45X advanced manufacturing production credit established by the...more

US Treasury to Propose Regulations on Domestic Content Bonus Credit

On May 12, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on the domestic content bonus credit for certain clean energy...more

US Treasury to Propose Regulations on Energy Community Bonus Adders

On April 4, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on qualifying for the energy community bonus credit under Sections...more

US Treasury Issues Proposed Regulations on Section 30D Clean Vehicle Credit

Electric vehicle and electric battery manufacturers and critical mineral producers will want to take note of a notice of proposed rulemaking (NPRM) on Section 30D of the Internal Revenue Code of 1986, as amended, released by...more

Tax Credits for Electric Vehicles: What’s Changed with the US IRA?

President Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law on August 16, 2022. Among other things, the IRA expands the federal income tax credits available to promote the development and use of renewable...more

US Inflation Reduction Act of 2022: Carbon Capture Use and Sequestration Provisions

President Biden signed the Inflation Reduction Act of 2022 (IRA) into law on Tuesday, August 16, 2022. Among other things, the IRA expands the federal tax credits available to promote renewable energy and revises the...more

The Green Energy Tax Incentives of the Inflation Reduction Act of 2022

Last Wednesday night, after weeks of negotiations, US Senators Joe Manchin and Chuck Schumer reached a deal on an energy and healthcare bill titled the Inflation Reduction Act of 2022 (the “Act”). The Act includes extensive...more

Manchin’s BBB Redux-tion Act – The Inflation Reduction Act of 2022

This week, after weeks of negotiations, Senators Manchin and Schumer reached a deal on an energy and healthcare bill titled the Inflation Reduction Act of 2022 (the “Act”).  The Act includes extensive provisions relating to a...more

US House Rules Committee Modifies the “Build Back Better Act”

In less than a week, the Rules Committee of the US House of Representatives (the “Rules Committee”) released two versions of modified legislative text of H.R. 5376, the Build Back Better Act. The first version was released on...more

US House Ways and Means Committee Proposes Substantial Green Energy Support

On the night of September 10, 2021, the House Ways and Means Committee (the “Committee”) released legislative text covering a range of green energy tax incentives (the “Bill”) that it hopes will be enacted through the budget...more

IRS Ruling Provides Guidance on Carbon Capture Equipment and Section 45Q Credit

On July 1, 2021, the US Internal Revenue Service (the “IRS”) released Revenue Ruling 2021-13 (the “Ruling”), which provides additional guidance on the definition of “carbon capture equipment” for purposes of the carbon...more

IRS Ruling Provides Guidance on Carbon Capture Equipment and Section 45Q Credit

On July 1, 2021, the US Internal Revenue Service (the “IRS”) released Revenue Ruling 2021-13 (the “Ruling”), which provides additional guidance on the definition of “carbon capture equipment” for purposes of the carbon...more

Energy Tax Implications of the Administration’s FY2022 Budget Tax Proposals

On May 28, 2021, the Biden administration (the “Administration”) released its FY2022 budget (the “Budget”), which includes proposed investments related to infrastructure, clean energy and research and development. Alongside...more

Recent Legislative Proposals Could Drastically Change US Energy Taxation

Over the past number of weeks, a variety of legislative proposals, from both sides of the aisle, have been released that, if enacted, could drastically impact the US energy industry and, in many cases, the taxation of energy...more

Recent Legislative Proposals Could Drastically Change US Energy Taxation

Over the past number of weeks, a variety of legislative proposals, from both sides of the aisle, have been released that, if enacted, could drastically impact the US energy industry and, in many cases, the taxation of energy...more

Energy Tax Implications of New Infrastructure and Tax Plans

The American Jobs Plan - On March 31, 2021, the Biden administration released the American Jobs Plan (the “Infrastructure Plan”), which is a proposal that, if ultimately enacted, aims to modernize outdated infrastructure,...more

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