Now that final regulations on the transferability of energy tax credits under the Inflation Reduction Act have been issued by the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS), many investors...more
On April 25, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for...more
The IRS launched its Inflation Reduction Act (IRA) Pre-Filing Registration Tool in late 2023 for elective (direct) payments under Section 6417 and tax credit transfers under Section 6418 of the Internal Revenue Code....more
Under the IRA, select renewable energy credits are transferrable, including to individuals and pass-through entities. The transferees of these credits are subject to the passive activity rules of Section 469 of the...more
On June 14, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed and temporary regulations regarding the transfer elections for certain tax credits available...more
Through its recent passage of the Infrastructure Investment and Jobs Act (the “Act”), Congress resolved an open question regarding the extent to which cryptocurrency transactions should be subject to information reporting...more