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Internal Revenue Code (IRC) Renewable Energy

Mitchell, Williams, Selig, Gates & Woodyard,...

Implementation of Section 45Z/Clean Fuels Production Credit: Energy Marketers of America Comments on Internal Revenue Service's...

The Energy Marketers of America (formerly, Petroleum Marketers Association of America) (“EMA”) submitted April 10th comments to the Internal Revenue Service (“IRS”) addressing its: …notice of intent to propose regulations...more

Morgan Lewis

The State of Play for Energy Storage Tax Credits

Morgan Lewis on

The energy storage industry has continued to progress over the course of 2024 and into 2025, buoyed in significant part by the federal income tax benefits in the form of tax credits enacted under the Inflation Reduction Act...more

Beveridge & Diamond PC

Key Areas for Regulatory Engagement With the Trump Administration’s Emphasis on Biofuels

Overview - Among its energy policy priorities, early executive orders, and other actions, the Trump administration has reinforced its commitment to expanding the U.S. biofuels sector, which typically has strong bipartisan...more

Holland & Knight LLP

Navigating the Domestic Content Requirements Under Evolving IRS Guidance

Holland & Knight LLP on

The IRS issued Notice 2025-08 on Jan. 16, 2025, which provides updated guidance regarding the domestic content requirements under Sections 45, 48, 45Y and 48E of the Internal Revenue Code – the investment tax credits and...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

Latham & Watkins LLP on

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

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

McDermott Will & Emery

IRS Roundup January 13 – 17, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...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

Baker Botts L.L.P.

Final Section 45V Clean Hydrogen Production Tax Credit Regulations: A Closer Look

Baker Botts L.L.P. on

On January 3, 2025, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) released long-awaited final regulations regarding the clean hydrogen production tax credit under section 45V of the...more

K&L Gates LLP

Proposed Texas Senate Bills Have Potential Negative Impacts on Wind and Solar

K&L Gates LLP on

Renewable energy developers should be aware of the proposed legislation in Texas that, if passed, will significantly impact existing wind and solar facilities as well as development-stage projects. Senate Bill 819 (SB 819)...more

Beveridge & Diamond PC

Treasury and the IRS Finalize Clean Electricity Tax Credit Rules

Beveridge & Diamond PC on

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

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

Latham & Watkins LLP

IRS Finalizes Hydrogen Tax Credit Regulations

Latham & Watkins LLP on

The final regulations adopt the general framework established in the proposed regulations issued in December 2023, but with several significant modifications....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

Vinson & Elkins LLP

Treasury Releases Guidance and GREET Model for the Section 45Z Clean Fuel Production Credit

Vinson & Elkins LLP on

On January 10, 2025, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) continued their flurry of new guidance by releasing IRS Notice 2025-10 (the “Notice”) concerning the clean fuel...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

K&L Gates LLP

Department of the Treasury and the Internal Revenue Service Issue Final Regulations on Section 45V Clean Hydrogen Production Tax...

K&L Gates LLP on

On 3 January 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Rules) implementing the Section 45V Clean Hydrogen Production Tax Credit (Section 45V tax...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

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

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