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Proposed Treasury Regulations Provide Guidance on Stock Buyback Excise Tax for Redemptions and M&A Transactions

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

Treasury Department Issues Guidance on Round Two of §48C Advanced Energy Tax Credit Program

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

IRS Opens Registration Portal for the Elective Payment or Transfer of Tax Credits

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

Energy & Sustainability Legal Feature – Increased Opportunity for More Taxpayers to Access Clean Energy Tax Credits and Related...

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

IRS Issues Notice 2023-44 Clarifying the 48C Program Application Process and Timeline

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

IRA Update: IRS Releases Limited Guidance on Low-Income Community Adder and Establishes Allocation Program Needed to Make the...

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

IRA Update: IRS Announces Updated Reference Standard for Energy Efficient Commercial Building Property Deduction Under Section...

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

Public Comments Requested on Additional Aspects of the IRA Clean Energy Tax Incentives, including Clean Hydrogen Production,...

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

Last Call: Public Comments on Inflation Reduction Act Clean Energy Tax Incentives Are Requested By November 4

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

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

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

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