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Treasury Proposes Clean Fuel Production Credit Guidance

On 4 February 2026, the US Department of the Treasury and the Internal Revenue Service (Treasury) released highly anticipated proposed regulations implementing the Section 45Z Clean Fuel Production Tax Credit (Section 45Z),1...more

IRS Issues Guidance on Prohibited Foreign Entity Safe Harbors and Material Assistance Calculation for Clean Energy Tax Credits

On 12 February 2026, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2026-15 (the Notice), to provide interim guidance for determining whether a project has received material...more

US Government Announces Historic $80 Billion Nuclear Partnership with Westinghouse Electric Company, Cameco Corporation, and...

On 27 October 2025, President Donald Trump announced an US$80 billion strategic partnership between the US Department of Commerce, Westinghouse Electric Company (Westinghouse), and its owners Brookfield Asset Management...more

Understanding the New Prohibited Foreign Entity Rules for Clean Energy Tax Credits

Introduction - The One Big Beautiful Bill Act (OBBBA) makes major changes to the Internal Revenue Code’s (Tax Code) clean energy tax provisions, particularly to the provisions that were extended, expanded, and established as...more

IRS Notice 2025-42: What Renewable Developers Need to Know on Beginning of Construction Rules

On 15 August 2025 the Internal Revenue Service (IRS) released Notice 2025-42 (the Notice), which restricts the methods that developers of wind and solar projects can use to determine whether they have begun construction for...more

Navigating the One Big Beautiful Bill Act: Critical Updates to Clean Energy Credits

President Donald J. Trump signed H.R. 1, the One Big Beautiful Bill Act (OBBBA), into law on 4 July 2025 in an afternoon signing ceremony at the White House (Pub. L. No. 119-21). Senate Majority Leader John Thune (R-SD)...more

Going Nuclear–Industry Outlook and Issues

The nuclear energy industry continues to gain momentum and has a strong outlook for 2025 and beyond. This positive forecast is buoyed by support from both major political parties, increased demand, technical advancements, and...more

Department of the Treasury and the Internal Revenue Service Issue Final Regulations on Section 45V Clean Hydrogen Production Tax...

On 3 January 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Rules) implementing the Section 45V Clean Hydrogen Production Tax Credit (Section 45V tax...more

The Department of Treasury Releases Direct Pay Guidance on Clean Energy Tax Credits

Final Rules Address Eligibility and Process; Proposed Rules Provide Workaround Allowing Tax Exempts to Partner With Others on Projects - The Department of Treasury (Treasury) and the Internal Revenue Service (IRS) recently...more

Tax Credit Revolution: US Treasury and IRS Propose Section 45V Hydrogen Production Tax Credit Regulations

Members of the K&L Gates Hydrogen, Power, Tax, and Tax Policy teams speak with Sandi Safro Osborn, Assistant General Counsel of the Edison Electric Institute, about the proposed regulations the Treasury Department and...more

US Treasury Department Releases Proposed Section 45V Hydrogen Tax Credit Regulations

On 22 December 2023, the US Treasury Department (Treasury) released the highly anticipated Proposed Regulations relating to the Clean Hydrogen Production Credit (hydrogen credit) under the US Internal Revenue Code of 1986, as...more

Recent Treasury Proposed Regulations' Application to Qualified Offshore Wind Properties

On 17 November 2023, the US Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) updating rules for the investment tax credit (ITC) under Code1...more

Highlights of Section 48 Investment Tax Credit Proposed Regulations

On 17 November 2023, the US Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) updating rules for the investment tax credit (ITC) under...more

Treasury and IRS Propose Regulations for Inflation Reduction Act's Low-Income Communities Bonus Credit Program

On 1 June 2023, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) issued a notice of proposed rulemaking (NOPR) regarding the Low-Income Communities Bonus Credit Program (Program) established...more

Domestic Content Guidance Offers Much Needed Answers but Also Raises Uncertainty about Qualification Requirements

Introduction - On 12 May 2023, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released guidance for the domestic content bonus credit under Sections 45, 45Y, 48, and 48E of the Internal...more

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