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Energy Newsletter - February 2020

U.S. Government’s Continued Focus on Large Ship Air Emissions - The U.S. Environmental Protection Agency (“EPA”) and the U.S. Coast Guard (“USCG”) continue to signal interest in addressing air pollution from large ships...more

Anticipated IRS Guidance on Section 45Q Rumored to Be Just Around the Corner

Investors and project sponsors await proposed regulations and interim guidance under Section 45Q of the Internal Revenue Code to resolve uncertainty and unlock significant carbon capture, utilization and storage market...more

IRS and Treasury Release Final Opportunity Zone Regulations

On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more

Energy Newsletter - July 2019

Choose Your Own Adventure: Farmouts of International Oil & Gas Interests and the AIPN 2019 Model Form - When I teach about the Association of International Petroleum Negotiator’s (AIPN) Model International Farmout...more

Foreign Guarantees and Collateral in Play Following Finalization of Deemed Dividend Regulations

On May 22, 2019 the Treasury Department and the Internal Revenue Service released regulations (the “Final Regulations”) finalizing and making certain technical changes to proposed regulations (the “Proposed Regulations”,...more

IRS and Treasury Release Second Round of Qualified Opportunity Zone Guidance

On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more

IRS and Treasury Issue Long-Awaited Proposed Guidance on Qualified Opportunity Fund Rules

On October 19, 2018, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under new section 1400Z-2 of the Internal Revenue Code (the “Code”),...more

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