News & Analysis as of

Foreign Entities Clean Energy

Hogan Lovells

Implications of new FEOC restrictions on clean energy tax credits

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On May 12, 2025, the House Ways and Means Committee reported out a significant tax reconciliation bill, known as the “One, Big, Beautiful Bill.” While the bill aims to extend and enhance several provisions from the 2017 Tax...more

Baker Botts L.L.P.

The One Big Beautiful Bill Proposes to Severely Restrict Clean Energy Tax Incentives

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On May 22, 2025, the House passed the legislation entitled “The One Big Beautiful Bill” (the “BBB”) that would, if enacted into law, severely restrict clean energy tax incentives. This client update addresses the BBB’s...more

Mayer Brown

House Reconciliation Bill Amends Clean Energy Provisions of the IRA

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On May 22, 2025, the House of Representatives passed its reconciliation bill, H.R. 1, entitled “One Big Beautiful Bill Act” (the “legislation”), which significantly amends the clean energy provisions that were enacted as part...more

Paul Hastings LLP

House Bill Accelerates Phaseout of Clean Energy Tax Credits and Restricts Leasing and Transferability

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On May 22, 2025, the U.S. House of Representatives passed House Bill 1, officially titled the “One Big Beautiful Bill Act” (OBBBA). This budget reconciliation bill includes significant energy-related provisions that would...more

Jones Day

The One, Big, Beautiful Bill: Impact on Clean Energy Tax Credits

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The One, Big, Beautiful Bill would significantly limit tax credits for clean energy and manufacturing introduced or expanded under the Inflation Reduction Act of 2022....more

McGuireWoods LLP

Tax Bill Proposes Phasedowns in ITC and PTC, Limits on Transferability

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On May 12, 2025, the House Ways and Means Committee released a draft of the Republican-sponsored 2025 tax bill, which addresses a number of renewable and clean energy tax credit matters previously extended in the Inflation...more

ArentFox Schiff

IRA Developments to Watch in the EV and Battery Supply Chain for 2025

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The incoming Trump Administration’s approach to the Inflation Reduction Act (IRA) and tax policies is generating significant interest within the electric vehicle (EV) sector. Generally, reports indicate that some Republican...more

Perkins Coie

IRS Clean Vehicle Tax Credit Rule Adds Hurdles for Domestic Electric Vehicle Manufacturing

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The Internal Revenue Service (IRS) published a final rule on May 6, 2024, defining eligibility requirements for the clean vehicle credit under Section 30D of the Internal Revenue Code, enacted by the Inflation Reduction Act...more

Jones Day

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

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The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Sheppard Mullin Richter & Hampton LLP

Should You Be Concerned About Foreign Entities of Concern?

Grants and tax credits, who doesn’t love them? The Bipartisan Infrastructure Law (BIL) is full of them, and, recent Department of Energy (DOE) Notification of a Proposed Interpretive Rule provides guidance on who will get to...more

Eversheds Sutherland (US) LLP

DOE, Treasury and IRS issue guidance regarding foreign entity of concern for section 30D tax credit eligibility

On December 4, 2023, the Department of Energy (DOE), Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published related proposed guidance on the eligibility of an electric vehicle for the section...more

Jones Day

Proposed Guidance Clarifies "Foreign Entity of Concern" Restrictions for Clean Vehicle Credit

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New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...more

Troutman Pepper Locke

Guidance Suggests U.S. Clean Vehicle Subsidies Require Disengagement From China Supply Chains

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On December 1, the U.S. Department of Energy (DOE) released long-awaited proposed guidance defining “foreign entity of concern” (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Simultaneously, the U.S....more

Akin Gump Strauss Hauer & Feld LLP

Clean Vehicle Tax Credit – Foreign Entity of Concern Rules Proposed

On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more

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