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U.S. Treasury Internal Revenue Code (IRC)

Holland & Knight LLP

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

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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

Hogan Lovells

U.S. Department of Treasury issues final 45X advanced manufacturing production credit rules

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Final 45X rules provide some important clarifications as to what is considered as produced in the U.S. for components and technical elements for certain components such as solar, battery storage, inverters, wind turbines and...more

Cadwalader, Wickersham & Taft LLP

Charging Ahead or Stalling Out? Clean Energy Credits Await Key Guidance

The Inflation Reduction Act of 2022 (the “IRA”) allows firms to develop and sell clean energy tax credits. In our last update, available here, we discussed the release of the long-awaited guidance package on the new...more

Holland & Knight LLP

Treasury Department, IRS Release Section 30C Proposed Regulations

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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

Paul Hastings LLP

Treasury Issues Proposed Regulations on the Section 30C Alternative Fuel Vehicle Refueling Property Credit

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The Alternative Fuel Vehicle Refueling Property Credit available under Section 30C of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Section 30C Credit”), was originally enacted by the...more

Cadwalader, Wickersham & Taft LLP

Basket Contract Listed Transactions

On July 12, 2024, Treasury and the IRS published proposed regulations (the “Proposed Regulations”) that would identify certain basket contract transactions as well as transactions substantially similar thereto as “listed...more

Holland & Knight LLP

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

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The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

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

Eversheds Sutherland (US) LLP

Proposed regulations reduce flexibility of foreign currency mark-to-market election

On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more

Eversheds Sutherland (US) LLP

Short tax year savior: Rev. Proc. 2024-34

Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes - On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....more

Freeman Law

Propuesta de Reglamentación para Fideicomisos Extranjeros Análisis de la Sección 643(i) del IRC

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El 8 de mayo de 2024, la Secretaría de Hacienda de los Estados Unidos (“Treasury Department”) dio a conocer propuestas de reglamentos que abordan la clasificación, tributación y requisitos de información para fideicomisos...more

Jones Day

U.S. Tax Court Invokes Loper Bright for the First Time

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The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

The Wagner Law Group

A New “One Percent” Tax Issue – Proposed IRS Regulations on the Excise Tax on Stock Repurchases

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The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”), in an April 2024 follow-up to IRS Notice 2023-2, issued proposed regulations dealing with the one-percent excise tax under Internal Revenue...more

McDermott Will & Emery

Weekly IRS Roundup August 12 – August 16, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12, 2024 – August 16, 2024. ...more

Eversheds Sutherland (US) LLP

In Rawat, DC Circuit construes the Code and regulations without deference, providing an example of statutory and regulatory...

On July 23, 2024, the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) released a decision in Rawat v. Commissioner (available here). The case considers whether the portion of a non-US...more

Eversheds Sutherland (US) LLP

Proposed regulations add certain basket contracts to list of listed transactions

On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more

Holland & Knight LLP

Eyes on Energy Tax Update: Second Quarter 2024

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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

Cadwalader, Wickersham & Taft LLP

Supreme Court Overruling of Chevron Fuels Regulatory Uncertainty

On June 28, the U.S. Supreme Court sent shockwaves through the legal system by overturning one of the foundational precedents of American administrative law.  In Loper Bright Enterprises v. Raimondo, the Court, in a 6-3...more

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Gray Reed

IRS Further Combats Basket Contract Transactions with Proposed Regs

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The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more

McDermott Will & Emery

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

McDermott Will & Emery on

On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

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The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Dechert LLP

Stock Repurchase Excise Tax Regulations Finalized: Effect on RICs

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On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations on the reporting of the one-percent (1%) stock repurchase excise tax imposed by new section 4501 of the Internal...more

Holland & Hart - Employers' Lawyers

IRS Issues Final Prevailing Wage and Apprenticeship Regulations

On June 25, 2024, the Internal Revenue Service and U.S. Department of Treasury published final Treasury Regulations (“Final Regulations”) in the Federal Register on the prevailing wage and registered apprenticeship...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury and IRS Issue Proposed Regulations Regarding the Clean Energy Production and Clean Electricity Investment Credits Under...

The proposed regulations provide the initial guidance for new tax credits that go into effect in 2025 for clean electricity facilities using various technologies that achieve net-zero greenhouse gas (GHG) emissions. Under...more

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