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House Passes 2025 Reconciliation Bill – Further Restricting IRA Tax Benefits

After an intense 21-hour House Rules Committee markup, early in the morning of May 22, 2025, the House passed H.R. Con. Res. 14, 119th Cong. (2025) (the “Reconciliation Bill”), which makes significant revisions to the...more

House Ways and Means Committee Approves Markup of Reconciliation Bill

Early this morning, the House Ways and Means Committee (the “Ways and Means Committee”) approved its recently proposed markup of H.R. Con. Res. 14, 119th Cong. (2025) (the “Reconciliation Bill”). Among many other items, this...more

Tax Law (and Controversy) Under the Trump Administration

As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more

Treasury Releases Final Regulations for the Tech-Neutral PTC and ITC

On January 7, 2025, the U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 10024) (the “Final Regulations” and the preamble thereto, the...more

Final Hydrogen Regulations Provide Multiple Paths for Production, But The Three Pillars and Other Obstacles Remain

On January 10, 2024, the Department of the Treasury (“Treasury”) published the final regulations governing the section 45V Clean Hydrogen Production Tax Credit (“Final Regulations”). The Final Regulations tackle many of the...more

Taxpayers Find Helpful Clarity in Final 45X Regulations, as Critical Minerals and Electrode Active Material Producers Strike Gold

On October 24, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Final 45X Regulations”) regarding the Advanced Manufacturing Production Tax...more

State of the IRA – Pre-Election Review

As Vinson & Elkins prepares to host its “Energy Transition and IRA Conference” in New York on November 7, 2024 (just two days after the upcoming presidential election), we ask ourselves, where have we been and where might we...more

Charging Forward: Proposed Regulations Issued for EV Charging & Alternative Fuel Refueling Property

On September 18, 2024, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) (1) issued proposed regulations (the “Proposed Regulations”) providing guidance to taxpayers on the Alternative...more

Energy Makers Find Limited Answers in Bonus Tax Credit Guidance

The domestic content bonus is one of the Inflation Reduction Act’s most powerful tax incentives, but so far is proving to be one of the most difficult to earn. The Treasury Department and IRS released Notice...more

The Very Timely PWA Requirements Finalized

On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage...more

Treasury Releases Notice on the Section 45Z Clean Fuel Production Credit

On May 31, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service continued to churn out Inflation Reduction Act of 2022 (“IRA”)1 guidance by releasing Notice 2024-49 (the “Notice”) regarding the...more

Treasury Releases Proposed Regulations on Tech-Neutral PTC and ITC

On May 29, 2024, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations (REG-119283-23) (the “proposed regulations”) regarding the clean electricity production...more

Domestic Content Safe Harbor Released

On May 16, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued Notice 2024-41 (the “Notice”), which provides supplemental guidance on the domestic content bonus credit...more

Final Direct Pay Regulations Released

On March 5, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Final Direct Pay Regulations”) regarding the direct pay election for certain tax...more

Treasury Releases Long Awaited Hydrogen Guidance

Just in time for the Christmas holiday, early this morning the U.S. Internal Revenue Service (“IRS”) and Department of Treasury (“Treasury”) released highly anticipated regulations governing the Section 45V Clean Hydrogen Tax...more

Treasury Issues Proposed Regulations on 45X Advanced Manufacturing Production Credit

On December 14, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) providing additional guidance to taxpayers on the advanced...more

Treasury Releases a Swath of Guidance on the Investment Tax Credit

On November 17, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations [REG-132569-17] regarding the definition of “energy property” and related rules...more

Treasury Issues Proposed Regulations for IRA Labor Requirements

On August 29, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) providing proposed rules governing the prevailing wage and...more

3 Developments That May Usher In A Nuclear Energy Revival

Nuclear energy is experiencing a resurgence. As the world grapples with how best to address climate change, nuclear has found a seat at the table as a viable, zero-carbon energy source. While the appetite in the U.S. for...more

Full Speed Ahead: The Inflation Reduction Act at One Year

It’s the largest climate legislation in US history, with many complex provisions. But let’s start with the big picture: A year on from the Inflation Reduction Act becoming law, is it living up to its promise?...more

[Webinar] The Inflation Reduction Act – 1 Year Later - September 13th, 12:00 pm - 1:00 pm CT

In this presentation, we will discuss substantive updates and guidance released on IRA credits and monetization and provide a market update....more

Guidance Clears the Way for Direct Pay – Treasury Releases Preliminary “Elective Payment” Regulations

On June 14, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations and temporary regulations regarding the direct pay election1 for certain tax credits...more

Transfer Away! Treasury Releases Preliminary Ground Rules for Tax Credit Transfers

On June 14, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed and temporary regulations regarding the transfer elections for certain tax credits available...more

Unlocking the Opportunity of Low-Carbon Hydrogen: Investment, Incentives, and Collaboration

Hydrogen can play a vital role in the transition to a carbon-neutral economy, and momentum for it has never been stronger. Both governments and companies see the enormous potential of low-carbon hydrogen for storing energy,...more

Highly Anticipated Domestic Content Bonus Guidance Released

On May 12, 2023, the Department of the Treasury (the “Treasury”) and Internal Revenue Service (the “IRS”) issued Notice 2023-38 (the “Notice”), providing guidance on the rules taxpayers must satisfy to qualify for the...more

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