The Inflation Reduction Act of 2022 (the “IRA” or the "Act”) introduces several provisions which may well be of interest to battery manufacturers. Most of these are contained in the new “Advanced Manufacturing Production...more
The Inflation Reduction Act of 2022 (the “IRA”) released by U.S. Senate Democrats on July 27, 2022 would, if enacted, provide a number of financial incentives to encourage the purchase of electric and hydrogen fuel cell...more
On January 6, 2021, the IRS issued final regulations relating to section 45Q. This is the fourth piece of guidance from the IRS relating to section 45Q, following IRS Notice 2020-12, Revenue Procedure 2020-12, the Proposed...more
1/29/2021
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Critical Infrastructure Sectors ,
Energy Projects ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
IRS ,
Production Tax Credit ,
Tax Credits ,
Tax Planning ,
Urban Planning & Development
Background. - While the fossil fuel industry continues to enjoy a number of tax incentives, a new generation of tax incentives were enacted in the early 2000s to promote the use of renewable energy. These include the...more
9/23/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Energy Projects ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Real Estate Development ,
Renewable Energy ,
Tax Credits ,
Tax Planning
On May 2, 2019, the Internal Revenue Service ( the “IRS”) released Notice 2019-32 (the “Notice”) which requested comments for Carbon Oxide Sequestration Section 45Q of the Internal Revenue Code....more
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more
6/21/2019
/ Advanced Pricing Agreements ,
Business Entities ,
Corporate Counsel ,
Corporate Taxes ,
Cost-Sharing ,
Income Taxes ,
Intangible Property ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Multinationals ,
Offshore Companies ,
Section 482 ,
Stock-Based Compensation ,
Tax Court
In February, the Internal Revenue Service (IRS) released its FY 2018 Annual Report and announced a record-breaking year for the agency’s whistleblower program. Overall, whistleblowers provided information that contributed to...more
On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more
2/2/2017
/ Consumer Financial Products ,
Derivatives ,
Dividend-Equivalent Transactions ,
Exchange-Traded Products ,
Financial Institutions ,
Financial Markets ,
Internal Revenue Code (IRC) ,
IRS ,
Master Limited Partnerships ,
Partnerships ,
Qualified Derivatives Dealers (QDDs) ,
Section 871(m) ,
Securities ,
SIFMA ,
Stocks
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more
The increasing use of corporate inversions, whereby a company via merger achieves 20 percent or more new ownership, claims non-U.S. residence, and is then permitted to adopt that country’s lower corporate tax structure and...more
Section 7623 of the Internal Revenue Code (the “Code”), added in 1954, authorizes the Treasury Secretary to pay an award as he deems necessary for “(1) detecting underpayments of tax, or (2) detecting and bringing to trial...more