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Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more

IRS Releases 2023 Section 45 Production Tax Credit Amounts

The IRS on June 21, 2023, released 2023 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code. That guidance provides that: Section 45 allows a renewable energy PTC for generating electricity from...more

IRS Issues Updated Energy Community Bonus Guidance

The IRS on June 15, 2023, updated its energy community bonus guidance by issuing Notice 2023-45 and Notice 2023-47. The IRS also recently issued energy community bonus guidance in Notice 2023-29. (For a summary of Notice...more

Treasury Department and IRS Release Direct Pay and Transferability Guidance

The U.S. Department of the Treasury and IRS on June 14, 2023, released two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax credits under Section 6417 of the Internal Revenue Code (Elective Payment...more

Treasury Department, IRS Release Low-Income Community Bonus Credit Proposed Rules

The U.S. Department of the Treasury and IRS on May 31, 2023, released a Notice of Proposed Rulemaking (NPRM) regarding the low-income community bonus credit under Section 48 of the Internal Revenue Code. The NPRM requests...more

Break Out Your Calculator: IRS Releases Domestic Content Bonus Credit Guidance

Following the release of energy community bonus credit and low-income community bonus credit guidance, the U.S. Department of the Treasury and IRS recently provided taxpayers with the domestic content bonus credit guidance....more

The New IRS Selectivity Criteria for Advance Price Agreements and Renewals

The IRS has announced new rules relating to the acceptance of Advance Pricing Agreement (APA) and renewal requests. On April 25, 2023, the IRS published interim guidance (the Interim Guidance), effective as of that date, that...more

Eyes on Energy Tax Update: First Quarter 2023

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

Treasury Department, IRS Release Clean Vehicle Tax Guidance

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

IRS Energy Community Bonus Guidance Provides Welcome Clarity

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

Treasury Department Issues 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 to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more

Treasury Department Releases Section 48C Guidance with Billions in Tax Credits Up for Grabs

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

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

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

Notice 2023-7: First Peek at Corporate AMT Guidance

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 Most Interesting International Tax Proposals in Biden's FY 2023 Budget

This Holland & Knight alert discusses the intersection of President Joe Biden's proposed changes to the U.S. tax code, as announced in connection with his fiscal year (FY) 2023 budget, and work underway on the global stage...more

President Biden Unveils FY 2023 Budget Request

The White House on March 28, 2022, released President Joe Biden's $5.8 trillion proposed budget for federal spending in fiscal year (FY) 2023. The president's budget proposal serves as a fiscal blueprint for the...more

U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status

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

Agreement on Global Tax Reform: What Happened and What's Next

Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20...more

Biden Administration's FY 2022 Budget and International Tax Changes

A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy

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

U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits

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

Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming

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

Biden's American Families Plan Proposes Income Tax Hikes

The American Families PlanĀ is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and...more

Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework

The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more

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