Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. ...more
The U.S. Department of the Treasury and IRS have released several pieces of guidance regarding the tax incentives for clean vehicles provided under Sections 30D (new clean vehicle credit), 25E (previously owned vehicle...more
4/14/2023
/ Automotive Industry ,
Batteries ,
Comment Period ,
Electric Vehicles ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
IRS ,
Lithium Batteries ,
Manufacturers ,
Mineral Extraction ,
NPRM ,
Supply Chain ,
Tax Credits ,
Tax Incentives ,
U.S. Treasury ,
Zero-Emission Vehicles
After much anticipation, the Internal Revenue Service (IRS) released guidance regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E, which also is applicable for purposes of Section 48C. The guidance...more
The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more
3/28/2023
/ Comment Period ,
Internal Revenue Code (IRC) ,
IRS ,
Manufacturers ,
New Guidance ,
Proposed Regulation ,
Semiconductors ,
Tax Credits ,
Tax Incentives ,
Technology Sector ,
U.S. Treasury
Reinstated by the Inflation Reduction Act of 2022 (IRA), Section 48C of the Internal Revenue Code provides $10 billion in credits for qualifying advanced energy projects, $4 billion of which must be allocated projects located...more
The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more
2/2/2023
/ Acquisitions ,
Affiliates ,
Comment Period ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Fair Market Value ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Liquidation ,
Reorganizations ,
Stock Redemption ,
Stock Repurchases ,
U.S. Treasury
As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more
The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty). It provides for purposes of...more
8/9/2021
/ EU ,
Foreign Equivalency Determination ,
International Tax Issues ,
IRS ,
Member State ,
NAFTA ,
Tax Treaty ,
U.S. Treasury ,
UK ,
UK Brexit ,
United States-Mexico-Canada Agreement (USMCA)
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more
6/4/2021
/ Appropriations Bill ,
Biden Administration ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Proposed Legislation ,
Tax Reform ,
U.S. Treasury
The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important...more
6/3/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more
5/7/2021
/ Biden Administration ,
Congressional Committees ,
Congressional Investigations & Hearings ,
Corporate Taxes ,
Cryptocurrency ,
Income Taxes ,
IRS ,
Large Business & International Division (LB&I) ,
Offshore Funds ,
Proposed Legislation ,
Tax Audits ,
Tax Evasion ,
Tax Haven ,
Tax Loopholes ,
Tax Reform ,
Wealth Tax