On April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate...more
5/24/2024
/ Acquisitions ,
Excise Tax ,
Fair Market Value ,
Individual Retirement Account (IRA) ,
Initial Public Offering (IPO) ,
IRS ,
Leveraged Buyout ,
Liquidation ,
Mergers ,
Proposed Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Special Purpose Acquisition Companies (SPACs) ,
Stocks ,
U.S. Treasury
The highly anticipated guidance for the second round of allocations (Round Two) under the US Treasury’s §48C Qualifying Advanced Energy Project Tax Credit program was released this week pursuant to IRS Notice 2024-36, with...more
The Internal Revenue Service (IRS) recently launched a new online registration portal allowing taxpayers to begin the registration process that must be completed in order for a taxpayer to elect to transfer a credit (under...more
This past summer, the Treasury and Internal Revenue Service (IRS) published proposed Treasury Regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA) designed to enable...more
A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered, this is often (at least in...more
A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax related factors that need to be considered, this is often (at least in...more
On May 31, 2023, the Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released Notice 2023-44 (“Notice”) to provide additional guidance on Section 48C, a revised and expanded allocation-based...more
Inflation Reduction Act Overview -
$740 billion package focused on inflation and deficit reduction, health care, and energy security & climate change -
• Raises $737 billion in revenue through a new 15% corporate book...more
4/20/2023
/ Affordable Care Act ,
Clean Energy ,
Climate Change ,
Deficit Reduction ,
Energy Sector ,
Healthcare ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
Prevailing Wages ,
Production Tax Credit ,
Tax Credits ,
Wages
On Monday, February 13, 2023, the Department of the Treasury (Treasury) and the IRS published Notice 2023-17 (the Notice), establishing the program for allocating environmental justice capacity limitations (the Allocation...more
On Friday, December 23, 2022, the IRS published Announcement 2023-1, 2023-1 IRB 1 (the “Announcement”), which sets forth a new reference standard for energy efficient commercial building (“EECB”) property for purposes of the...more
On Monday, December 12, 2022, the IRS released Revenue Procedure 2022-42 (the “EV Guidance”), which sets forth reporting requirements for manufacturers and sellers of new or previously owned clean vehicles or qualified...more
On November 3, 2022, the U.S. Department of Treasury (Treasury) and Internal Revenue Service (IRS) released three Notices requesting public comments by December 3, 2022, on certain additional aspects of the clean energy tax...more
On October, 5, 2022, the U.S. Department of Treasury (Treasury) and Internal Revenue Service (IRS) published six Notices requesting public comments by November 4, 2022 on certain of the clean energy tax incentives included in...more
11/3/2022
/ Carbon Capture and Sequestration ,
Clean Energy ,
Energy Tax Incentives ,
Greenhouse Gas Emissions ,
Hydrogen Power ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Manufacturers ,
Prevailing Wages ,
Production Tax Credit ,
Public Comment ,
Tax Incentives ,
U.S. Treasury
On July 27, 2022, Senator Joe Manchin and Senate Majority Leader Chuck Schumer announced that they have reached an agreement on a budget reconciliation bill (the Inflation Reduction Act of 2022, the “Act”). Although the Act...more
8/2/2022
/ Alternative Minimum Tax ,
Capital Gains Tax ,
Carried Interest Tax Rates ,
Clean Energy ,
Energy Tax Incentives ,
Foreign Corporations ,
Inflation Adjustments ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy
In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more
10/12/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
Capital Gains ,
Controlled Foreign Corporations ,
Estate Tax ,
Gift Tax ,
GILTI tax ,
Green Book ,
Income Taxes ,
International Tax Authority ,
OECD ,
Qualified Business Income ,
SALT ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
Taxation ,
U.S. Treasury ,
Ways and Means Committee