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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 Guidance and GREET Model for the Section 45Z Clean Fuel Production Credit

On January 10, 2025, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) continued their flurry of new guidance by releasing IRS Notice 2025-10 (the “Notice”) concerning the clean fuel...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

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

Energy Credit Transferability Regulations Finalized

On April 25, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for...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 Issues Final Regulations on Low-Income Communities Bonus

On August 10, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations (the “Final Regulations”)1 providing additional guidance to taxpayers on the “Low-Income...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

Treasury Issues Proposed Regulations on Low-Income Communities Bonus

On May 31, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued Proposed Treasury Regulations 110412-23 (the “Proposed Regulations”), providing additional guidance on...more

Treasury Issues Additional Guidance on Section 48C Advanced Energy Project Tax Credit

On May 31, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued Notice 2023-44 (the “Notice”), providing additional guidance on the program established under section...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

Treasury’s New EV Guidance Rewards Domestic Manufacturing

On March 31, 2023, the Department of Treasury (the “Treasury”) issued Proposed Treasury Regulation 120080-22 (the “Proposed Regulations”) under section 30D of the Internal Revenue Code of 1986, as amended (the “Code”), with...more

Treasury Issues IRA Guidance on Section 48C Advanced Energy Project Credit

On February 13, 2023, the Department of Treasury (the “Treasury”), along with the Internal Revenue Service (the “Service”) and the Department of Energy (the “DOE”), issued Notice 2023-18 (the “Notice”), establishing a program...more

Offshore Wind — The Current State of Affairs

I. Introduction - Renewable energy development and the “energy evolution” continue to make a splash in energy infrastructure, legislation, and investment. And, among renewable energy technologies, offshore wind may be set...more

New IRS Guidance On Carbon Capture Projects Answers Some Questions, Raises Others

The IRS published Revenue Ruling 2021-13 on July 1, 2021, addressing a series of issues on the Section 45Q tax credit for carbon capture projects. Specifically, the Revenue Ruling focuses on a methanol plant and tackles...more

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