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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

U.S. Supreme Court Rulings Affect Challenges to Tax Regulations

Upon closing its October 2023 term, the U.S. Supreme Court issued two significant opinions – despite neither being a tax case – that will have broad consequences for taxpayers seeking to challenge tax regulations and other...more

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

IRS Targets Owners of Professional Sports Franchises Regarding Tax Reporting

Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...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

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

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

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

Breaking Down the Section 48 Investment Tax Credit Proposed Regulations

The U.S. Department of the Treasury and IRS on Nov. 17, 2023, released long-awaited proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code. Section...more

Section 48 Proposed Regulations Detail Treatment of Qualified Biogas Property

The U.S. Department of the Treasury on Nov. 17, 2023, issued proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code (Code) that, following passage...more

Treasury, IRS Release Proposed Regulations and Procedures for Clean Vehicle Credit Transfers

The U.S. Department of the Treasury and IRS on Oct. 6, 2023, released proposed regulations on the transfer of clean vehicle credits under Internal Revenue Code Section 25E (for previously owned clean vehicles) and Section 30D...more

Highlights of the Proposed Regulations on IRA Prevailing Wage and Apprenticeship Requirements

The U.S. Department of the Treasury and IRS on Aug. 29, 2023, announced proposed regulations regarding increased credit or deduction amounts for which taxpayers can qualify by meeting prevailing wage and registered...more

Eyes on Energy Tax Update: Second Quarter 2023

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

Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more

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