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Internal Revenue Code (IRC) New Guidance

Jones Day

Taxing Tangle: U.S. IRS Releases Guidance for Clean Hydrogen Production Tax Credit

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The U.S. Internal Revenue Service ("IRS") has released proposed regulations regarding the Clean Hydrogen Production Tax Credit introduced in the Inflation Reduction Act of 2022 ("IRA"). The proposed regulations provide more...more

Bricker Graydon LLP

Final Warning: Distributions to Beneficiaries Must Begin in 2025

Bricker Graydon LLP on

The retirement plan industry has been wrestling with the changes to required minimum distribution (RMD) provisions made by the SECURE Act and SECURE 2.0. One issue in particular has caused considerable confusion....more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Proskauer - Tax Talks

Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to...

Proskauer - Tax Talks on

On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more

Holland & Knight LLP

IRS Updates Energy Community Bonus Tax Credit Guidance

Holland & Knight LLP on

The IRS released additional guidance on June 7, 2024, in the form of Notice 2024-48 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...more

Holland & Knight LLP

Breaking Down the New Domestic Content Safe Harbor Guidance

Holland & Knight LLP on

The IRS issued Notice 2024-41 on May 16, 2024, which provides updated guidance regarding the domestic content bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The new notice modifies previously...more

Jones Day

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

Jones Day on

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Holland & Knight LLP

Guidance, Model Provide Additional Clarity for 40B Sustainable Aviation Fuel Tax Credit

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS released Notice 2024-37 on April 30, 2024, regarding the Sustainable Aviation Fuel (SAF) Tax Credit found at Section 40B of the Internal Revenue Code as an income tax credit and...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

Troutman Pepper

Treasury and IRS Release Further Guidance on Energy Community Enhancements Under IRA

Troutman Pepper on

On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore...more

King & Spalding

Guidance on Section 45V Clean Hydrogen Production Tax Credit

King & Spalding on

The trajectory of the hydrogen sector in the United States hinges on a critical question: what criteria will be used to define the term “clean hydrogen” for tax purposes? As previously outlined in our Field Guide to Clean...more

Eversheds Sutherland (US) LLP

IRS Notice 2024-6 provides guidance on sustainable aviation fuel credits

The Inflation Reduction Act of 2022 established sustainable aviation fuel (SAF) tax credits to benefit United States producers and importers of certain fuel mixtures containing SAF. On December 15, 2023, the Internal Revenue...more

Holland & Knight LLP

IRS, Treasury Department Release New Section 40B Sustainable Aviation Fuel Credit Guidance

Holland & Knight LLP on

The IRS and U.S. Department of the Treasury released on Dec. 15, 2023, Notice 2024-06 regarding Section 40B of the Internal Revenue Code. Effective for fuel mixtures sold or used after Dec. 31, 2022, and before Jan. 1, 2025,...more

Davis Wright Tremaine LLP

New IRS Guidance on Long-Term, Part-Time Employee Retirement Plan Participation

New proposed regulations clarify how employers should implement retirement plan eligibility rules for long-term, part-time ("LTPT") employees. While some questions remain, the proposed regulations provide a number of welcome...more

Perkins Coie

Treasury Releases First Installment of Long-Awaited Guidance on Donor-Advised Funds

Perkins Coie on

Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

McDermott Will & Emery

Weekly IRS Roundup October 30 – November 3, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 30, 2023 – November 3, 2023. ...more

Cadwalader, Wickersham & Taft LLP

Guidance on Limited Partnership Exception May Be Near

On September 29, 2023, Treasury released the 2023-2024 Priority Guidance Plan, which included “Guidance under section 1402(a)(13),” signaling the government’s intention to finally clarify the confusion surrounding the limited...more

McDermott Will & Emery

Weekly IRS Roundup October 16 – October 20, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 16, 2023 – October 20, 2023...more

McDermott Will & Emery

Weekly IRS Roundup September 11 – September 15, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 11, 2023 – September 15, 2023...more

ArentFox Schiff

Money (That’s What I Want): IRA’s Direct Pay Mechanism Benefits Tax-Exempt Entities

ArentFox Schiff on

The Inflation Reduction Act (IRA), which recently celebrated its one-year anniversary, presents new opportunities for tax-exempt and other organizations to directly benefit from renewable energy tax credits, including...more

Bricker Graydon LLP

To Roth or Not to Roth - That is No Longer the Question for Some Catch-Up Eligible Individuals

Bricker Graydon LLP on

IRS guidance issued last week delays the implementation of mandatory Roth catch-up contributions. As outlined in our blog post earlier this year, SECURE 2.0 amended the catch-up contribution provisions of the Code....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

IRS Emphasizes Health FSA and Dependent Care Assistance Program Substantiation Requirements

On April 28, 2023, the Internal Revenue Service’s (IRS) Office of Chief Counsel released guidance reiterating claims substantiation rules for health flexible spending arrangements (health FSAs) under Internal Revenue Code...more

Holland & Knight LLP

Eyes on Energy Tax Update: Second Quarter 2023

Holland & Knight LLP on

The second quarter of 2023 saw continued developments as a result of the enactment of the Inflation Reduction Act of 2022 (IRA), court activity and announcements from federal agencies. Below, we summarize the updates you need...more

Bricker Graydon LLP

IRS Releases Guidance on Elective Payments

Bricker Graydon LLP on

On Wednesday, June 14, 2023, the IRS released its long-awaited initial guidance and proposed regulations regarding the newly created direct payment election methodology. The federal government created this new “elective...more

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