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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

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 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

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

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

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

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

New Immediate Expensing Regulations Present Opportunities and Questions - Following up on 2018 proposed regulations, the...

The Treasury Department and Internal Revenue Service have issued final and proposed regulations (collectively, the new regulations) under section 168(k) of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and...more

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