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Internal Revenue Code (IRC) Inflation Reduction Act (IRA) U.S. Treasury

Vinson & Elkins LLP

Tax Law (and Controversy) Under the Trump Administration

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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

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

New IRS Guidance on Domestic Content Bonus Credit

The U.S. Department of the Treasury and the Internal Revenue Service have issued Notice 2025-08 (the “First Updated Elective Safe Harbor”), offering new guidance on the bonus credit for projects using domestically produced...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

Orrick, Herrington & Sutcliffe LLP

Treasury and IRS Release Guidance on Clean Fuel Production Credit

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released a notice of intent to propose regulations and a notice providing the annual emissions rate table for the Clean Fuel...more

Latham & Watkins LLP

Treasury Circulates Draft Regulations for Section 45Z Clean Fuel Production Credit

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A new tax credit is proposed to calculate a fuel’s emissions factor based on its full carbon life cycle of production. Notices 2025-10 and 2025-11 (Notices), released on January 10, 2025, outline the intention of the...more

Holland & Knight LLP

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

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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

Beveridge & Diamond PC

Treasury and the IRS Finalize Clean Electricity Tax Credit Rules

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The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) finalized regulations on the clean electricity production tax credit and clean electricity investment tax credit under sections 45Y and 48E...more

Troutman Pepper Locke

Treasury and IRS Issue Updated Domestic Content Guidance Under IRA and First Updated Elective Safe Harbor

Troutman Pepper Locke on

On January 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-08 (Notice), which provides an updated safe harbor (First Updated Elective Safe Harbor) that modifies and otherwise...more

Holland & Knight LLP

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

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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

Jones Day

New Guidance on the Commercial EV Tax Credit

Jones Day on

In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...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

Troutman Pepper Locke

Treasury and IRS Issue Final Regulations on Clean Electricity Production and Investment Tax Credits

Troutman Pepper Locke on

On January 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published final regulations providing further guidance on the clean electricity production credit under Section 45Y and the clean...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

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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

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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

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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 45Z Clean Fuel PTC Guidance

Holland & Knight LLP on

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

Mayer Brown

IRS Releases Final Energy Property Regulations Under Section 48 Investment Tax Credit

Mayer Brown on

On December 4, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations, TD 10015, (the “Final Regulations”), which provide guidance on the definition of energy...more

Holland & Knight LLP

Proposed Regulations Provide Clarity on Tax Treatment of Entities Wholly Owned by Tribal Governments

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The U.S. Department of the Treasury and IRS issued the Proposed Regulations on Oct. 9, 2024, providing long-awaited guidance on entities wholly owned by Tribal governments and organized or incorporated exclusively under the...more

Holland & Knight LLP

Key Highlights of the Section 48 ITC Final Regulations

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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

Jones Day

Final Regulations Issued in Final Days of Congress: Clean Hydrogen Production Tax Credit

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The Department of Treasury and the Internal Revenue Service issued final regulations regarding the Section 45V clean hydrogen production credit....more

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