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Taxing Tangle: U.S. IRS Releases Guidance for Clean Hydrogen Production Tax Credit

The U.S. Internal Revenue Service ("IRS") has released proposed regulations regarding the Clean Hydrogen Production Tax Credit introduced in the Inflation Reduction Act of 2022 ("IRA"). The proposed regulations provide more...more

Proposed Treasury Regulations Provide Guidance on New Clean Electricity Production and Investment Tax Credits

The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more

Proposed IRS Regulations on Tax Credits for Renewable-Energy Investments Include Wage and Apprenticeship Requirements

In Short - The Background: The Inflation Reduction Act provides for robust tax incentives on qualifying renewable-energy construction projects. In order to claim the full amount of such tax credits on qualifying projects,...more

Guidance Clarifies Requirements for Energy Tax Credits' Domestic Content Bonus

The U.S. Department of the Treasury has issued interim guidance outlining forthcoming proposed regulations regarding the domestic content bonus credit available to clean energy projects under the Inflation Reduction Act of...more

Proposed Regulations Address Deductibility of Business Interest Expense - Important guidance issued on the new 30 percent...

On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more

Proposed Treasury Regulations Permit Foreign Subsidiary Credit Support for U.S. Multinational Financings

The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign corporate subsidiary ("CFC") for deemed dividends triggered when the CFC provides...more

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