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
The Final Regulations provide relief with respect to “impracticable-to-trace” battery materials.
The new guidance provides additional detail for the transition rule applicable to qualified manufacturers, including as...more
The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications.
The registration portal for transferring tax credits is open, and no significant changes have...more
5/6/2024
/ Clean Fuels Program (CFP) ,
Final Rules ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Passive Activity ,
Registration Requirement ,
Regulatory Standards ,
Renewable Energy Incentives ,
S-Corporation ,
Tax Credits ,
Tax Returns ,
U.S. Treasury
Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more
3/19/2024
/ Business Entities ,
Comment Period ,
Internal Revenue Code (IRC) ,
IRS ,
Joint Ownership ,
Partnerships ,
Proposed Regulation ,
Regulatory Agenda ,
Tax Credits ,
Tax Reform ,
Taxation ,
U.S. Treasury
The proposed regulations go beyond the use of the GREET model by requiring the use of “energy attribute certificates” (EACs) to prove eligibility for the credit under section 45V of the Internal Revenue Code (IRC). The use of...more
1/2/2024
/ Clean Energy ,
Department of Energy (DOE) ,
Energy Tax Incentives ,
European Commission ,
Greenhouse Gas Emissions ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury ,
Zero Emission Credits
The proposed regulations provide important clarity on the distinction between substantial and superficial modification for purposes of determining eligible components produced by the taxpayer, along with guidance as to...more
12/22/2023
/ Anti-Abuse Rule ,
Clean Energy ,
Component Parts Doctrine ,
Engineering ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Manufacturers ,
Minerals ,
Proposed Legislation ,
U.S. Treasury
The proposed regulations add new definitions to clarify what is required under foreign entity of concern (FEOC) compliance.
The Revenue Procedure provides guidance to qualified manufacturers on reporting and other...more
The proposed regulations offer helpful guidance for taxpayers seeking to take advantage of the ITC under IRC section 48.
The proposed regulations add new definitions to clarify the scope of recently added qualifying...more
The proposed regulations under the Infrastructure Investment and Jobs Act (IIJA) expand the definition of “broker” to include anyone who provides facilitative services which effectuate sales.
Not surprisingly, centralized...more
The proposed regulations adopt the Department of Labor’s published rates for prevailing wages for the relevant type of construction in the geographic location of the project.
The proposed regulations provide additional...more
9/12/2023
/ Apprenticeships ,
Construction Industry ,
Davis-Bacon Act ,
Department of Labor (DOL) ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Prevailing Wages ,
Proposed Regulation ,
Recordkeeping Requirements ,
Safe Harbors ,
U.S. Treasury
The new law generally imposes a 15% alternative minimum tax on book income of corporations with book income in excess of $1 billion.
Public companies will generally be subject to a 1% excise tax on stock buybacks. ...more
8/26/2022
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
CFCs ,
Corporate Taxes ,
Excise Tax ,
Financial Statements ,
Inflation Reduction Act (IRA) ,
IRS ,
Joe Biden ,
OECD ,
Private Equity Firms ,
Proposed Rules ,
Share Buybacks ,
Shareholders ,
Tax Reform