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Treasury Department Issues Final Section 48D Guidance on CHIPS Act Semiconductor Tax Incentive

The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code (Code) to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the U.S. The credit is equal to...more

Treasury Department, IRS Release Section 45X Advanced Manufacturing Production Credit Final Regulations

The U.S. Department of the Treasury and IRS on Oct. 24, 2024, released Final Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. The Final Regulations are effective 60...more

Treasury Department, IRS Release Section 30C Proposed Regulations

The U.S. Department of the Treasury and IRS on Sept. 19, 2024, released proposed regulations under Section 30C of the Internal Revenue Code providing important clarity on the changes made by the Inflation Reduction Act (IRA)....more

Treasury, IRS Release Proposed Regulations Under Section 30C

The U.S. Department of the Treasury and IRS on Sept. 18, 2024, released proposed regulations under Section 30C of the Internal Revenue Code regarding the Alternative Fuel Vehicle Refueling Property Credit. The proposed...more

IRS Releases Long-Awaited Section 45Q LCA Procedures

The IRS on July 24, 2024, released Notice 2024-60, which provides Section 45Q guidance for utilization of carbon dioxide and other carbon oxides. The Notice addresses the information that must be included in the required life...more

Eyes on Energy Tax Update: Second Quarter 2024

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Renewable and Alternative Energy Tax Team that provides highlights of important developments. The Renewable and Alternative Energy Tax Team also...more

IRS Rules 3 Utilities Cannot Reduce NOL Carryforwards for Tax Allocation Payments

Following the initial public release of private letter ruling (PLR) 20242002 as part of a state rate proceeding, on June 28, 2024, the IRS publicly released that ruling, as well as two companion rulings obtained by other...more

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

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

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

IRS: Use of "Attrition Allowance" to Calculate Rate Base Violates Normalization Consistency Rules

Consistent with a state commission's existing regulatory policy, a utility's rate base for the first two years of the three-year rate cycle was computed using traditional cost-of-service/rate of return principles....more

Treasury, IRS Issue Inbound Corporation Stock Repurchase Excise Tax Proposed Regulations

Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise...more

Treasury Department, IRS Issue Additional Section 45V Clean Hydrogen PTC Guidance

The U.S. Department of the Treasury Department and IRS on April 10, 2024, issued a supplemental notice of proposed rulemaking (NPRM) under the Internal Revenue Code's Section 45V clean hydrogen production tax credit (PTC)....more

Inflation Reduction Act Direct Pay Rules Finalized

The U.S. Department of the Treasury and IRS released final regulations under Section 6417 of the Internal Revenue Code, as enacted by the Inflation Reduction Act (IRA). Section 6417 allows certain taxpayers to elect to...more

Treasury Department and IRS Release Final Regulations on the Direct Payment of Tax Credits

The U.S. Department of the Treasury and IRS on March 5, 2024, released final regulations regarding the direct payment of tax credits under Section 6417 of the Internal Revenue Code (Elective Payment of Applicable Credits)....more

IRS Updates and Modernizes Rules Governing Utility Securitizations

Since the issuance of Revenue Procedure (Rev. Proc.) 2005-62, many utilities have used securitizations authorized by state law to secure collections of stranded costs upon the retirement of certain generation plants or costs...more

Treasury Department, IRS Correct Section 48 Proposed Regulations on Qualified Biogas Property

The U.S. Department of the Treasury and IRS on Feb. 16, 2024, released a correction to Internal Revenue Code Section 48 Proposed Regulations relating to the new investment tax credit (ITC) for biogas. The correction provides...more

Inflation Reduction Act Direct Pay and Transfer Pre-Filing Registration Is Open for Business

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

Treasury, IRS Release Section 30C Alternative Fuel Vehicle Refueling Property Credit Guidance

The U.S. Department of the Treasury and IRS on Jan. 19, 2024, released Notice 2024-20, stating their intent to issue proposed regulations regarding the Alternative Fuel Vehicle Refueling Property Credit under Section 30C of...more

Eyes on Energy Tax Update: Fourth Quarter 2023

Eyes on Energy Tax Update is a quarterly publication of the Holland & Knight Renewable and Alternative Energy Tax Team that provides highlights of important developments. The Renewable and Alternative Energy Tax Team also...more

Project Labor Agreement Requirement for Large-Scale Construction Becomes Effective Jan. 22

As enacted by the Biden Administration in February 2022, Executive Order (EO) 140631 and its implementing final rule2 require that all awardees of federal construction contracts for which the total estimated cost of the...more

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

Treasury, IRS Release Section 45V Clean Hydrogen PTC Proposed Regulations

The U.S. Department of the Treasury and IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the Inflation...more

An In-Depth Look at Section 45X Proposed Regulations

The U.S. Department of the Treasury and IRS on Dec. 14, 2023, released Proposed Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. (See Holland& Knight's previous...more

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

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

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more

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