News & Analysis as of

Comment Period Inflation Reduction Act (IRA)

Latham & Watkins LLP

Healthcare Life Sciences Drug Pricing Digest - May 2025 #2

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Our Drug Pricing and Market Access team tracks recent developments in healthcare reform, the Medicaid Drug Rebate Program, the 340B Program, Medicare, and state law....more

Holland & Knight LLP

Treasury, IRS Release Proposed Regulations Under Section 30C

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The U.S. Department of the Treasury and IRS on Sept. 18, 2024, released proposed regulations under Section 30C of the Internal Revenue Code regarding the Alternative Fuel Vehicle Refueling Property Credit. The proposed...more

Cadwalader, Wickersham & Taft LLP

Everything You Need to Know About Energy Tax Credit Sales

The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits.  ...more

Foley Hoag LLP - Energy & Climate Counsel

IRS Issues Guidance and Requests Comment on Provisional Emission Rate Process for Hydrogen Tax Credit

On April 10, 2024, Department of Treasury and the Internal Revenue Service (collectively, “IRS”) issued further guidance on the “Provisional Emission Rate” or “PER” process for the Inflation Reduction Act’s (“IRA”) Hydrogen...more

Holland & Knight LLP

Inflation Reduction Act Direct Pay Rules Finalized

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The U.S. Department of the Treasury and IRS released final regulations under Section 6417 of the Internal Revenue Code, as enacted by the Inflation Reduction Act (IRA). Section 6417 allows certain taxpayers to elect to...more

Foley Hoag LLP - Energy & Climate Counsel

New York’s Inflation Reduction Act “Surplus” and How to Expand Distributed Solar Beyond 10 Gigawatts

The New York Public Service Commission (“PSC”) is considering recommendations by the New York State Energy Research and Development Authority (“NYSERDA”) to use existing NY-Sun Program funding to deploy distributed solar...more

Davis Wright Tremaine LLP

EPA Seeks Comments on "Clean" Label for Construction Industry

Inflation Reduction Act pledged millions to label program intended to cut climate pollution linked to manufacturing of construction products and materials - The Environmental Protection Agency ("EPA") is seeking public...more

Akin Gump Strauss Hauer & Feld LLP

Proposed Clean Hydrogen Guidance: Limitations on Credit Availability for Green Hydrogen Projects and Paths Forward

Guidance recently issued by the Department of the Treasury and the Internal Revenue Service (IRS) in proposed regulations (REG-117631-23) will (if held to be final) have a significant impact on green hydrogen projects in the...more

Faegre Drinker Biddle & Reath LLP

Department of Treasury Issues Guidance on Section 45X Production Tax Credit

The U.S. Department of the Treasury, in conjunction with the Internal Revenue Service (IRS), released updated proposed guidance on the Section 45X Production Tax Credit (PTC). The guidance addresses specific requirements...more

Holland & Knight LLP

Section 48 Proposed Regulations Detail Treatment of Qualified Biogas Property

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The U.S. Department of the Treasury on Nov. 17, 2023, issued proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code (Code) that, following passage...more

Jones Day

Proposed IRS Regulations on Tax Credits for Renewable-Energy Investments Include Wage and Apprenticeship Requirements

Jones Day on

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

Seyfarth Shaw LLP

The IRS – Finally – Publishes a Notice of Proposed Rulemaking Clarifying Inflation Reduction Act Prevailing Wage and...

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Seyfarth Synopsis: This alert summarizes the IRS’s recent notice of proposed rulemaking on complying with prevailing wage and apprenticeship requirements under the Inflation Reduction Act and explains key provisions...more

Holland & Knight LLP

Treasury, IRS Issue Proposed Regulations on IRA Prevailing Wage and Apprenticeship Requirements

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Ten months after the release of initial guidance, the U.S. Department of the Treasury and IRS on Aug. 29, 2023, issued proposed regulations regarding increased credit or deduction amounts available for taxpayers satisfying...more

Brownstein Hyatt Farber Schreck

EPA Proposes Significant Revisions to GHG Reporting Requirements in Subpart W

When the Environmental Protection Agency (EPA) launched the Greenhouse Gas Reporting Program (GHGRP) in 2009, the objective was to collect and publicly report greenhouse gas emissions data across certain industries. Through...more

Eversheds Sutherland (US) LLP

Directions regarding Direct Pay - Proposed Regulations Released on Elective Payment for Inflation Reduction Act Renewable Energy...

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release much-anticipated guidance, including with respect to the monetization of energy tax credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a package of much-awaited guidance (the Guidance) consisting of (i) proposed regulations addressing the tax credit...more

Holland & Knight LLP

Treasury Department, IRS Release Clean Vehicle Tax Guidance

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The U.S. Department of the Treasury and IRS have released several pieces of guidance regarding the tax incentives for clean vehicles provided under Sections 30D (new clean vehicle credit), 25E (previously owned vehicle...more

Goodwin

CMS Issues Guidance and Solicits Comment on the 2026 Inflation Reduction Act Part D Negotiation Process

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On March 15, 2023, the Centers for Medicare & Medicaid Services (CMS) issued an initial guidance memorandum on the Medicare Drug Price Negotiation Program (Negotiation Program) created by the Inflation Reduction Act of 2022...more

Foley Hoag LLP - Energy & Climate Counsel

DOE Releases Draft Study Calling for More Interregional Transmission

On February 24, 2023, the U.S. Department of Energy (DOE) released for public comment a draft of its National Transmission Needs Study (“Needs Study”), which endorses boosting overall transmission capacity—and transmission...more

Epstein Becker & Green

Comments to CMS Guidance on the Medicare Prescription Drug Inflation Rebate Program Due March 11, 2023

On February 9, 2023, the Centers for Medicare & Medicaid Services (“CMS”) issued a fact sheet and its initial guidance documents addressing the Medicare Prescription Drug Inflation Rebate Program for Medicare Parts B and D...more

Wiley Rein LLP

Part 2: Submitting Comments on the Inflation Reduction Act’s Medicare Drug Rebate and Price Negotiation Program Guidance

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The Inflation Reduction Act of 2022 (IRA), signed into law last August, seeks to overhaul the way Medicare buys and pays for prescription drugs. A regulatory undertaking of this scope is certain to generate a great deal of...more

Goodwin

CMS Issues Proposed Guidance on Inflation Rebates Under Medicare Part B

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On February 9, 2023, the Centers for Medicare & Medicaid Services (CMS) released initial program guidance addressing the inflation rebate provisions of the Inflation Reduction Act of 2022 (IRA). These provisions apply to how...more

Goodwin

CMS Issues Proposed Guidance on Inflation Rebates Under Medicare Part D

Goodwin on

On February 9, 2023, the Centers for Medicare & Medicaid Services (CMS) released initial program guidance on the inflation rebate provisions of the Inflation Reduction Act of 2022 (IRA). These provisions apply to how Medicare...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

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The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Goodwin

CMS Issues First Request for Public Comments on the Medicare Drug Price Negotiation Program “Small Biotech” Exception - Due March...

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The Inflation Reduction Act’s (“IRA”) drug price negotiation provisions have captured the pharmaceutical and biotech industry’s attention. In part, the IRA allows the Centers for Medicare & Medicaid Services (“CMS”) to...more

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