The US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2026-15 (Notice), providing long-awaited guidance on certain foreign entity of concern (FEOC) rules enacted under the One,...more
The U.S. Department of the Treasury and the Internal Revenue Service (IRS) recently released proposed regulations under section 45Z of the Internal Revenue Code of 1986, as amended (Section 45Z). Section 45Z provides a...more
Notice 2026-1 (the Notice) provides important guidance under Section 45Q of the Internal Revenue Code of 1986, as amended (the Code), for taxpayers claiming that carbon oxides are stored in secure geological storage following...more
The One Big Beautiful Bill Act (which we discussed in a previous client alert) generally requires wind and solar facilities to begin construction before July 5, 2026, or be placed in service by December 31, 2027, to qualify...more
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (the OBBBA), which makes permanent or modifies key provisions of the 2017 Tax Cuts and Jobs Act (the TCJA) and scales back numerous energy tax...more