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U.S. Tax Court Invokes Loper Bright for the First Time

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

Treasury Department Finalizes 1% Corporate Stock Buyback Tax Reporting Rules

The Background: The U.S. Treasury Department ("Treasury") issued regulations finalizing the reporting requirements on the 1% corporate stock buyback tax and starting the clock on the tax's first filing and payment deadline....more

IRS Issues Final Prevailing Wage and Apprenticeship Regulations for Clean Energy Tax Credits

The Background: The Inflation Reduction Act ("IRA") created or enhanced various tax credits for qualifying renewable energy projects. However, a taxpayer loses 80% of otherwise-available IRA credits unless prevailing wage...more

Proposed Treasury Regulations Provide Guidance on New Clean Electricity Production and Investment Tax Credits

The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Internal Revenue Service Alters Its View on Section 355 Spin-Offs

The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Administration Finalizes Regulations on Clean Energy Tax Credit Transfers

The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more

Proposed Guidance Clarifies "Foreign Entity of Concern" Restrictions for Clean Vehicle Credit

New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...more

Much-Anticipated Tax Reporting Regulations on Digital Asset Transactions Issued

Proposed regulations addressing new tax reporting requirements for cryptocurrencies and other digital assets have been issued by the IRS and Treasury....more

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Guidance Clarifies Requirements for Energy Tax Credits' Domestic Content Bonus

The U.S. Department of the Treasury has issued interim guidance outlining forthcoming proposed regulations regarding the domestic content bonus credit available to clean energy projects under the Inflation Reduction Act of...more

Interim Guidance from the Treasury Department on the 1% Corporate Stock Buyback Tax

In Short - The Situation: A new nondeductible 1% excise tax imposed on certain stock repurchases (enacted as new section 4501 as part of the Inflation Reduction Act on August 12, 2022) (the "Stock Buy-back Excise Tax")...more

The Unshell Draft Directive: Only a Few Months Left to Comply?

A draft European Union ("EU") Directive tackling the use of shell entities for tax purposes is currently being negotiated, with potential corrective measures to be considered. ...more

Inflation Reduction Act: Impact on Electric Vehicle and Transportation Industries

The Inflation Reduction Act of 2022 (the "Act"), signed into law by President Biden this month, offers new or expanded tax incentives for buying electric vehicles ("EVs") and using or producing certain environmentally...more

The Inflation Reduction Act: Impact on Renewable Energy

The Inflation Reduction Act (the "Act"), signed into law by President Biden on August 16, 2022, will significantly impact clean energy. This White Paper contains a summary of the provisions most relevant to the renewable...more

Inflation Reduction Act of 2022: Corporate Minimum Tax

In Short - The Situation: On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 into law. The Act establishes a new 15% corporate minimum tax (the "CMT") on large U.S. corporations (generally...more

Inflation Reduction Act Expands the Carbon Capture and Sequestration Tax Credit

The Act breathes new life into Section 45Q, the federal carbon capture tax credit, available to taxpayers capturing and sequestering qualifying carbon dioxide and other carbon oxides and claimed over a 12-year period. The...more

Inflation Reduction Act Imposes Stock Buyback Tax

In Short - The Situation: On August 16, 2022, the Inflation Reduction Act of 2022 (the "Act") was signed into law, enacting a new nondeductible 1% excise tax on certain share repurchases (so-called "stock buybacks"). ...more

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Enacting President Biden's Infrastructure Bill: Opportunities in The Infrastructure Investment and Jobs Act

The Road Towards Better Infrastructure On November 15  2021, President Biden signed into the law the long-awaited Bipartisan Infrastructure Framework, The Infrastructure Investment and Jobs Act ("IIJA")....more

Speeding Toward an Infrastructure Bill: Analyzing the Infrastructure Investment and Jobs Act

The Road Toward Better Infrastructure - On August 1, 2021, the Senate proposed the Infrastructure Investment and Jobs Act, a $1.2 trillion infrastructure bill including $550 billion in new spending to improve the country's...more

France Expanding Tax Permanent Establishment Definition, Overturning Previous Case Law

The Situation: In December 2020, the French administrative supreme court issued a major decision expanding the permanent establishment ("PE") concept and criteria for both French corporate income tax ("CIT") and value-added...more

U.S. Treasury Department Releases Proposed Carried Interest Regulations

The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

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