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Key Highlights of the Section 761 Final Regulations and Impact on Section 6417 Direct Payments

Under Section 6417 of the Code, as enacted by the Inflation Reduction Act (IRA), certain taxpayers that fall within the statutory definition of "applicable entities" are allowed to elect to receive a direct payment (i.e.,...more

Treasury Department, IRS Release Section 45V Clean Hydrogen PTC Final Regulations

The U.S. Department of the Treasury and IRS on Jan. 3, 2025, released Final Regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

Key Highlights of the Section 48 ITC Final Regulations

The U.S. Department of the Treasury and IRS on Dec. 12, 2024, issued Final Regulations regarding the investment tax credit (ITC) for Section 48 of the Internal Revenue Code, including the ITC for energy generation, energy...more

Final Regulations Issued on Penalty Supervisory Approval

More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

Treasury Department, IRS Release Section 45V Clean Hydrogen PTC Final Regulations

The U.S. Department of the Treasury and IRS on Jan. 3, 2025, released final regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

Highlights of Final Regulations Under Section 45X Advanced Manufacturing Tax Credit

The U.S. Department of the Treasury and IRS on Oct. 28, 2024, published final regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (Final Regulations)....more

Treasury Department Issues Final Section 48D Guidance on CHIPS Act Semiconductor Tax Incentive

The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code (Code) to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the U.S. The credit is equal to...more

Treasury Department, IRS Release Section 45X Advanced Manufacturing Production Credit Final Regulations

The U.S. Department of the Treasury and IRS on Oct. 24, 2024, released Final Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. The Final Regulations are effective 60...more

Treasury Department, IRS Release Final Regulations on Direct Pay Under CHIPS Act Section 48D

The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the production of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more

Inflation Reduction Act Direct Pay Rules Finalized

The U.S. Department of the Treasury and IRS released final regulations under Section 6417 of the Internal Revenue Code, as enacted by the Inflation Reduction Act (IRA). Section 6417 allows certain taxpayers to elect to...more

Treasury Department and IRS Release Final Regulations on the Direct Payment of Tax Credits

The U.S. Department of the Treasury and IRS on March 5, 2024, released final regulations regarding the direct payment of tax credits under Section 6417 of the Internal Revenue Code (Elective Payment of Applicable Credits)....more

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