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President Trump's Executive Order on Unleashing American Energy: Potential Foreign Investors' Claims Against the United States

On January 20, 2025, President Donald Trump issued the Executive Order on Unleashing American Energy, pausing the disbursement of grants and loans under the Inflation Reduction Act ("IRA") and the Infrastructure Investment...more

New Guidance on the Commercial EV Tax Credit

In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...more

Draft Guidance on the Section 45Z Clean Fuel Production Credit

The Department of Treasury and the IRS have released Notices 2025-10 and 2025-11, outlining intended forthcoming proposed regulations for the Section 45Z clean fuel production credit introduced by the Inflation Reduction Act...more

Final Clean Electricity Production and Investment Tax Credit Regulations Provide Taxpayers With Welcomed Guidance

The Department of Treasury and the Internal Revenue Service released final regulations regarding the Section 45Y clean electricity production and Section 48E clean electricity investment tax credits....more

Final Regulations Issued in Final Days of Congress: Clean Hydrogen Production Tax Credit

The Department of Treasury and the Internal Revenue Service issued final regulations regarding the Section 45V clean hydrogen production credit....more

Final Regulations Clarify the Investment Tax Credit Rules

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations for the investment tax credit under section 48, providing guidance for projects that start construction by December 31, 2024....more

Final Regulations Expand Access to "Direct Pay" Elections for Energy Credits

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more

Final Regulations Clarify Requirements for the Advanced Manufacturing Production Credit

The Department of Treasury and the Internal Revenue Service ("IRS") issued final regulations regarding the advanced manufacturing production tax credit....more

The Climate Report | Third Quarter 2024

REGULATORY ISSUES & UPDATES - Update on Australia's New Climate-Related Financial Disclosure Regime - Australia's mandatory climate-related financial disclosure regime is inching closer to implementation after the proposed...more

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

Navigating the Emerging Market for Green Energy Tax Credits

The Inflation Reduction Act of 2022 (the "IRA")—President Biden's landmark climate change legislation—created or expanded tax credits for various renewable energy sources, including wind, solar, and hydropower, as well as for...more

U.S. Tax Court Invokes Loper Bright for the First Time

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

Supreme Court Upholds the Mandatory Repatriation Tax in Moore v. United States

The U.S. Supreme Court has affirmed the Ninth Circuit's decision in Moore v. United States, upholding the constitutionality of the mandatory repatriation tax enacted in 2017....more

IRS Issues Final Prevailing Wage and Apprenticeship Regulations for Clean Energy Tax Credits

The Background: The Inflation Reduction Act ("IRA") created or enhanced various tax credits for qualifying renewable energy projects. However, a taxpayer loses 80% of otherwise-available IRA credits unless prevailing wage...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

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Administration Finalizes Regulations on Clean Energy Tax Credit Transfers

The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more

Proposed Guidance Clarifies "Foreign Entity of Concern" Restrictions for Clean Vehicle Credit

New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...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

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...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

Tax Credits for Sale: Opportunities for Financing Renewable Energy and Carbon Reduction Projects Under the Inflation Reduction Act

The Inflation Reduction Act gives taxpayers two options for monetizing the Internal Revenue Code's energy-related tax credits—a "direct pay" election and the ability to sell credits to third parties for cash. These options...more

Inflation Reduction Act: Impact on Electric Vehicle and Transportation Industries

The Inflation Reduction Act of 2022 (the "Act"), signed into law by President Biden this month, offers new or expanded tax incentives for buying electric vehicles ("EVs") and using or producing certain environmentally...more

The Inflation Reduction Act: Impact on Renewable Energy

The Inflation Reduction Act (the "Act"), signed into law by President Biden on August 16, 2022, will significantly impact clean energy. This White Paper contains a summary of the provisions most relevant to the renewable...more

Inflation Reduction Act of 2022: Corporate Minimum Tax

In Short - The Situation: On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 into law. The Act establishes a new 15% corporate minimum tax (the "CMT") on large U.S. corporations (generally...more

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