News & Analysis as of

Internal Revenue Code (IRC) Inflation Reduction Act (IRA) Energy Sector

Orrick, Herrington & Sutcliffe LLP

Final Regulations Released for the Clean Electricity Low-Income Communities Bonus Credit Program

The U.S. Department of the Treasury and the Internal Revenue Service have published final regulations concerning the low-income communities bonus credit program under Section 48E(h) of the Internal Revenue Code of 1986, as...more

Orrick, Herrington & Sutcliffe LLP

Tech-Neutral Credits Final Regulations Released for Clean Electricity Production

The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) have released final regulations for two new tax credits under the Internal Revenue Code (Code), established by the Inflation Reduction Act...more

McGuireWoods Consulting

What’s On The Table For Budget Reconciliation?

On Jan. 16, 2025, a 51-page document attributed to the House Budget Committee was released with policy options and associated budgetary impacts for congressional committees to consider as they work through the reconciliation...more

Holland & Knight LLP

Questions and Answers: Initial Section 45Z Clean Fuel PTC Guidance

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Jan. 10, 2025, released initial guidance regarding the production tax credit (PTC) for clean fuels under Section 45Z of the Internal Revenue Code, as enacted by the Inflation...more

Holland & Knight LLP

Key Highlights of the Section 761 Final Regulations and Impact on Section 6417 Direct Payments

Holland & Knight LLP on

Under Section 6417 of the Code, as enacted by the Inflation Reduction Act (IRA), certain taxpayers that fall within the statutory definition of "applicable entities" are allowed to elect to receive a direct payment (i.e.,...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Hydrogen Production Tax Credit Regulations

On January 3, 2025, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Regulations) to implement the tax credit for the production of “qualified clean hydrogen”...more

Cadwalader, Wickersham & Taft LLP

Treasury Finalizes Key Energy Tax Credit Guidance Amid a Dry January

Enacted in August 2022, the Inflation Reduction Act (the “IRA”) expanded energy tax credits by increasing credit amounts across the board and broadening eligibility criteria to include new technologies....more

Eversheds Sutherland (US) LLP

Expected flurry of executive actions leaves open questions for the energy tax credits under the IRA at the start of Trump’s second...

On January 20, 2025, Donald J. Trump was inaugurated as the 47th President of the United States. As expected, President Trump took several executive actions in his first hours in office. The discussion below considers the...more

Holland & Knight LLP

Treasury Department, IRS Release Section 45V Clean Hydrogen PTC Final Regulations

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The U.S. Department of the Treasury and IRS on Jan. 3, 2025, released Final Regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

Baker Botts L.L.P.

Inflation Reduction Act Guidance: IRS and Treasury Release Final Regulations on the New Tech-Neutral Clean Energy Tax Credits

Baker Botts L.L.P. on

On January 15, 2025, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) published final regulations regarding the new “clean electricity production credit” under Internal Revenue Code...more

Paul Hastings LLP

IRS and Treasury Release Final Rules for Technology-Neutral Clean Electricity Credits Under Sections 45Y and 48E

Paul Hastings LLP on

The Inflation Reduction Act of 2022 introduced the Code Section 45Y production tax credit (CEPTC) for facilities that generate clean electricity with zero greenhouse gas (GHG) emissions and the Code Section 48E investment tax...more

Katten Muchin Rosenman LLP

US Treasury and IRS Unveil Proposed Regulations for Commercial EV Tax Credit, Sparking Questions on Recapture Provisions

On January 10, the US Treasury Department (Treasury) and the US Internal Revenue Service (IRS) released proposed regulations under Section 45W of the US Internal Revenue Code of 1986, as amended (the Code), which provides a...more

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Paul Hastings LLP

Treasury and IRS Finalize Clean Hydrogen Production Credit Regulations

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added the Section 45V production tax credit for the production of clean hydrogen (Section 45V) to the Internal Revenue Code of 1986, as amended. Section 45V provides a credit against...more

Holland & Knight LLP

Treasury Department, IRS Release Section 45W Clean Commercial Vehicle Guidance

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The U.S. Department of the Treasury and IRS released proposed regulations on Jan. 10, 2025, regarding the qualified commercial clean vehicle credit under Section 45W of the Internal Revenue Code, as enacted by the Inflation...more

Holland & Knight LLP

Key Highlights of the Section 48 ITC Final Regulations

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Dec. 12, 2024, issued Final Regulations regarding the investment tax credit (ITC) for Section 48 of the Internal Revenue Code, including the ITC for energy generation, energy...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – December 27, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23, 2024 – December 27, 2024....more

Husch Blackwell LLP

Carbon Capture: Tax Impacts of Utilization & Storage

Husch Blackwell LLP on

One promising solution to climate change is Carbon Capture, Utilization and Storage (“CCUS”). CCUS involves capturing carbon oxides, primarily carbon dioxide (CO2), for permanent storage or potential utilization. Interest in...more

A&O Shearman

Significant updates in Treasury's final energy credit regulations

A&O Shearman on

The U.S. Treasury Department and the Internal Revenue Service (“IRS”) published final regulations on December 4, 2024, defining “energy property” and rules applicable to energy credits (the investment tax credit, or the...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations on Section 48 Investment Tax Credits

On December 4, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) regarding the investment tax credit (ITC) under Section 48 of the...more

Holland & Knight LLP

Highlights of Final Regulations Under Section 45X Advanced Manufacturing Tax Credit

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Oct. 28, 2024, published final regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (Final Regulations)....more

Foley & Lardner LLP

IRS Releases Final Regulations for Section 45X Advanced Manufacturing Credit

Foley & Lardner LLP on

The Internal Revenue Service (“IRS”) and Department of the Treasury last week released final regulations (the “Final Regulations”) relating to the advanced manufacturing production tax credit under Section 45X (“45X Credits”)...more

ASKramer Law

Energy Tax Credits for a New World Part VIII: Monetizing Energy Tax Credits

ASKramer Law on

What is “monetization”? Monetization is the process by which property is converted into money or something else of value. In the context of the Inflation Reduction Act of 2022 (IRA), certain provisions can allow entities that...more

ASKramer Law

Energy Tax Credits for a New World Part VII: Low-Income Communities Bonus Credits

ASKramer Law on

What is the Low-Income Communities Bonus Credit? The Low-Income Communities Bonus Credit available through the Inflation Reduction Act of 2022 (IRA) is designed to increase the siting of, and access to renewable energy...more

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