On December 5, 2023, the US Supreme Court heard oral arguments in Moore v. United States, addressing the constitutionality of the section 965 transition tax, which was enacted in the Tax Cuts and Jobs Act of 2017. Section 965...more
12/27/2023
/ Apportionment ,
Constitutional Challenges ,
Controlled Foreign Corporations ,
International Tax Issues ,
Moore v US ,
Oral Argument ,
SCOTUS ,
Sixteenth Amendment ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Liability
The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more
On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more
7/3/2023
/ Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
Transfer of Interest ,
U.S. Treasury
The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more
On April 4, 2023, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-29(the Notice) to provide additional guidance on energy community bonus tax credits under IRC sections 45, 45Y,...more
4/11/2023
/ CERCLA ,
Coal-Fired Plants ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy ,
Safe Harbors ,
Tax Credits
On April 4, 2023, the IRS and the Department of Treasury released Notice 2023-29 (the Notice), which provides that proposed regulations are forthcoming regarding the energy community bonus tax credits under IRC sections 45,...more
On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (Service) issued Notice 2023-17 (Notice), establishing the 48(e) Low-Income Communities Bonus Credit Program (Program) with respect...more
3/13/2023
/ Community Development ,
Energy Projects ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
New Guidance ,
Solar Energy ,
Tribal Lands ,
U.S. Treasury ,
Wind Power
On February 17, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (the IRS) issued Notice 2023-20 (the Notice), to provide guidance that is intended to help avoid unintended adverse consequences to...more
On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-18 (Notice), which establishes the program to allocate $10 billion of tax credits that were added by the...more
2/17/2023
/ Biden Administration ,
Clean Energy ,
Climate Change ,
Energy Projects ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Manufacturers ,
Production Tax Credit ,
Renewable Energy ,
U.S. Treasury