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Biden Signs Climate Bill With Transformative Changes to Clean Energy Tax Incentives

The Inflation Reduction Act ushers in the largest clean energy tax credit package in US history. Key Points: • Wind and solar tax credits receive a multi-year extension at full rates, and solar projects are eligible...more

Key Senators Agree to Significantly Expand Tax Incentives for Clean Energy

The Inflation Reduction Act, which includes the most dramatic expansion of clean energy tax credits in recent history, would provide a multi-year extension of existing tax credits for wind and solar, increase tax credits for...more

IRS Gives Offshore Wind and Federal Land Projects More Time to Qualify for Tax Credits

Notice 2021-05 gives renewable energy developers 10 years to complete projects located offshore or on federal land. Key Points: ..Developers of offshore and federal land projects now have 10 years to complete their...more

COVID-19 Tax Relief Package Extends Renewable Power and Carbon Capture Tax Credits

Congress extends tax credits for certain renewables, and expands tax credits for offshore wind and waste energy recovery. Key Points: ..Production tax credits for onshore and offshore wind projects are extended at a 60%...more

Tax Reform: Final Regulations Clarify Framework for Determining Pass-Through Income Deduction

Treasury finalizes rules for key component of tax reform for pass-through trades and businesses. Key Points: ..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more

Tax Reform Update - Impact on Renewable and Energy Projects

Major tax overhaul will reshape the renewables and energy industries. Key Points: ..Sponsors must navigate new tax rules in search of lowest after-tax capital structures. ..A new cross-border tax threatens to...more

Treasury Issues Final and Temporary Regulations on Related-Party Debt Instruments

Seeking to curb “excessive” use of related-party debt, Treasury and IRS retain basic framework, but significantly narrow the scope, of the Proposed Regulations. On October 13, 2016, the US Department of the Treasury...more

IRS Issues Additional Guidance on “Begun Construction” Requirement for Wind Energy Credits

Latest guidance extends “continuity safe harbor” to four years and includes other taxpayer-friendly modifications and clarifications to existing guidance. On May 5, 2016, the Internal Revenue Service (IRS) issued...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

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