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 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