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Overview of the Proposed Regulations Addressing Direct Pay

As covered in our prior alerts, the Inflation Reduction Act[1] (IRA) modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable...more

Risks Associated with the Purchase of Renewable Energy Credits - Part II

As covered in our prior alert, the Inflation Reduction Act[2] (IRA) modified and reinstated existing renewable energy credits and enacted new renewable energy credits. The IRA also enacted two novel alternatives to tax equity...more

Overview of Renewable Energy Tax Credits Under the Inflation Reduction Act - Part I

In the United States, federal tax policy, through federal income tax credits, is one of the primary methods used to effectuate government subsidies for the development of renewable energy technology in the private sector....more

Inflation Reduction Act Provides Boost and Benefits to Carbon Capture Utilization and Storage Industry

​​​​​​​The newly passed Inflation Reduction Act of 2022 (IRA) is poised to transform the carbon capture utilization and storage (CCUS) industry through significant tax credits and benefits, including through enhancements to...more

[Podcast] Intellectual Property Tax Considerations at Home and Abroad

Businesses that conduct operations both inside and outside of the United States and own U.S. and non-US-related intellectual property (e.g., patents, copyrights, trademarks, etc.) routinely face uncertainty about whether some...more

Easing the Path Toward Carbon Sequestration: Revenue Ruling 2021-13

On July 1, 2021, the IRS released Revenue Ruling 2021-13 (Rev. Rul. 2021-13). That ruling (i) provided an example of the functionality-based definition of carbon capture equipment found in final Section 45Q Treasury...more

President Biden’s Plan for the Carbon Sequestration Tax Credit

Investment in Section 45Q tax partnerships may soon increase rapidly as the Biden administration aims to increase the Section 45Q tax incentive for carbon capture, utilization and sequestration. Specifically, President...more

Monetizing the Section 45Q Tax Credit: The Key to Carbon Sequestration

If there is to be rapid progress in limiting the increase of carbon dioxide (CO2) in the atmosphere, it will depend substantially on federal tax credits and state incentives for carbon capture and storage. For now, carbon...more

IRS Releases New Guidance on Credits for Sequestration of Carbon

If there is to be rapid progress in limiting the increase of carbon dioxide (CO2) in the atmosphere, it will depend substantially on federal tax credits and state incentives for carbon capture and storage. For now, carbon...more

Proposed Regulations Provide Guidance on Taxation of Carried Interests

On July 31, the IRS and the Treasury Department released long-awaited proposed regulations on the Section 1061 “carried interest” rules. The proposed regulations include extensive definitional and operational rules on the...more

8/19/2020  /  APIs , Carried Interest , IRS , U.S. Treasury

FAQs: COVID-19 – Federal and State Tax Updates (Updated #2)

Taxpayers May Delay Both Filing Tax Returns and Paying Some Taxes for 90 Days - Q: Congressional and Treasury Action to Date: What have Congress and the Treasury Department done in response to the COVID-19 crisis so far that...more

FAQs: COVID-19 – Federal and State Tax Updates (Updated)

Q: Congressional and Treasury Action to Date: What have Congress and the Treasury Department done in response to the COVID-19 crisis so far that may be of interest to businesses?...more

FAQs: COVID-19 – Federal and State Tax Updates

Q: Congressional Action to Date: What has Congress done in response to the COVID-19 crisis so far that may be of interest to businesses?...more

COVID-19 – Federal and State Tax Updates

Q – Filing of Federal Tax Returns: Must C corporation and individual U.S. federal income tax returns or extensions for the 2019 calendar year be filed by the April 15, 2020, due date?...more

New Tax Law Will Shape Future Environmental Settlements

A minor provision concerning deductibility in Public Law 115-97, commonly known as the Tax Cuts and Jobs Act (Act), may have significant impacts on administrative and judicial settlements between companies and the U.S....more

Preparing for the New Partnership Audit Rules

The Bipartisan Budget Act of 2015 substantially changed audit-related rules impacting entities taxed as partnerships, including both state-law partnerships and many limited liability companies (LLCs). The most significant...more

Highlights of Substantial Tax Changes in the Consolidated Appropriations Act, 2016

Expiring tax provisions and “extenders” legislation have become fairly common in recent years. The typical pattern involves institution of one- or two-year provisions (short-lived due to revenue issues) that have expired with...more

President Obama Signs "Fiscal Cliff" Legislation into Law

As you likely have heard, the President signed the American Taxpayer Relief Act (H.R. 8) (the "Act") on January 2, 2013. The Act, popularly known as the "fiscal cliff" legislation, permanently extends the Bush era tax cuts...more

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