Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
2/20/2026
/ Clean Energy ,
Energy Sector ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Proposed Regulation ,
Regulatory Agenda ,
Self-Employment Tax ,
Tax Court ,
Tax Credits ,
Tax Liability ,
Tax Litigation ,
Tax Reform
On February 3, 2026, the Treasury Department and the Internal Revenue Service (IRS) published proposed regulations regarding the clean fuel production credit under section 45Z of the Internal Revenue Code (Proposed...more
2/11/2026
/ Clean Energy ,
Energy Policy ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
One Big Beautiful Bill Act ,
Proposed Regulation ,
Proposed Rules ,
Renewable Energy ,
Renewable Fuel ,
Tax Credits ,
Tax Legislation ,
U.S. Treasury
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
1/15/2026
/ BEPS ,
Cross-Border Transactions ,
Customs ,
Customs and Border Protection ,
Customs Valuation ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
International Trade ,
IRS ,
New Guidance ,
New Regulations ,
OECD ,
Pillar 2 ,
Tariffs ,
Tax Litigation ,
Tax Reform ,
Transfer Pricing ,
USPS
As tariffs on goods imported into the United States keep changing, the interplay between customs values and transfer pricing has become more significant. Taxpayers with established transfer prices may be incentivized to seek...more
1/14/2026
/ Cross-Border Transactions ,
Customs ,
Imports ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
International Trade ,
IRS ,
New Guidance ,
Tariffs ,
Taxation ,
Transfer Pricing
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On August 15, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued much-anticipated guidance (Notice 2025-42) regarding the determination of when an applicable wind or solar facility is...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
7/16/2025
/ Business Taxes ,
Compensation ,
Corporate Taxes ,
Employee Benefits ,
Executive Compensation ,
Federal Budget ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Loper Bright Enterprises v Raimondo ,
New Legislation ,
SCOTUS ,
Tax Court ,
Tax Reform ,
Taxation ,
Trump Administration
On July 2, 2025, the Tax Court issued its unanimous reviewed opinion in JM Assets, LP v. Commissioner, 165 T.C. 1. It held that the Service did not timely issue a final partnership adjustment (FPA) to JM Assets, LP (JM...more
7/11/2025
/ Administrative Authority ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
Loper Bright Enterprises v Raimondo ,
Regulatory Agencies ,
SCOTUS ,
Statutory Interpretation ,
Tax Court ,
Taxation
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On July 1, 2025, the Senate passed One Big Beautiful Bill (OBBB) in a 51-50 vote, with Vice President J.D. Vance casting a tiebreaker vote. Although the House of Representatives previously passed its own version of OBBB (see...more
7/7/2025
/ China ,
Clean Energy ,
Energy Policy ,
Energy Projects ,
Federal Budget ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
New Legislation ,
Popular ,
Renewable Energy ,
Tax Credits ,
Trump Administration
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
The House of Representatives narrowly passed the One Big Beautiful Bill along party lines. The proposed bill would terminate or otherwise make significant changes to several of the energy tax credits created or expanded by...more
On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more
On November 5, 2024, Judge Goeke of the United States Tax Court issued an order granting the petitioners’ Motion for Reconsideration of Findings (Motion) in Schwarz v. Commissioner. On May 13, 2024, the Tax Court released...more
On July 23, 2024, the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) released a decision in Rawat v. Commissioner (available here). The case considers whether the portion of a non-US...more
8/14/2024
/ Appeals ,
Chevron Deference ,
Government Agencies ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
Regulatory Requirements ,
SCOTUS ,
Statutory Authority ,
Statutory Interpretation ,
U.S. Treasury
On July 24, 2024, the IRS issued Notice 2024-60, which sets forth the procedures for taxpayers to follow when claiming Section 45Q credits based on the “utilization” of carbon oxide. Taxpayers claiming credits based on...more
On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more
4/11/2024
/ Federal Taxes ,
Income Taxes ,
Investment Tax Credits ,
IRS ,
Manufacturing Facilities ,
Partnerships ,
Registration Requirement ,
S-Corporation ,
Semiconductors ,
Tax Liability ,
U.S. Treasury
On December 4, 2023, the Department of Energy (DOE), Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published related proposed guidance on the eligibility of an electric vehicle for the section...more
1/10/2024
/ Automotive Industry ,
Batteries ,
China ,
Clean Car Standards ,
Clean Energy ,
Department of Energy (DOE) ,
Electric Vehicles ,
Foreign Entities ,
Infrastructure Investment and Jobs Act (IIJA) ,
Iran ,
IRS ,
Minerals ,
Motor Vehicles ,
North Korea ,
Proposed Guidance ,
Russia ,
Tax Credits ,
U.S. Treasury
The Inflation Reduction Act of 2022 established sustainable aviation fuel (SAF) tax credits to benefit United States producers and importers of certain fuel mixtures containing SAF. On December 15, 2023, the Internal Revenue...more
On December 26, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pertaining to the clean hydrogen production credit (Clean Hydrogen...more
12/29/2023
/ Anti-Abuse Rule ,
Clean Energy ,
Electricity ,
Energy Projects ,
Energy Sector ,
Energy Storage ,
Hydrogen Power ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Utilities Sector
On November 17, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) relating to eligible energy property that qualifies for the section 48...more
On August 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) on the clean energy prevailing wage and apprenticeship (PWA) requirements...more
9/14/2023
/ Apprenticeships ,
Clean Energy ,
Climate Change ,
Davis-Bacon Act ,
Energy Projects ,
Energy Sector ,
Federal Contractors ,
Inflation Reduction Act (IRA) ,
IRS ,
Labor Regulations ,
Prevailing Wages ,
Proposed Regulation ,
Renewable Energy ,
Subcontractors ,
Tax Credits ,
U.S. Treasury
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
7/13/2023
/ Comment Period ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Proposed Regulation ,
Public Hearing ,
Renewable Energy ,
Semiconductors ,
Tax Credits ,
Tax Exempt Entities ,
Transfer of Interest ,
U.S. Treasury
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
7/3/2023
/ Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
Transfer of Interest ,
U.S. Treasury