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Treasury Department Finalizes 1% Corporate Stock Buyback Tax Reporting Rules

The Background: The U.S. Treasury Department ("Treasury") issued regulations finalizing the reporting requirements on the 1% corporate stock buyback tax and starting the clock on the tax's first filing and payment deadline....more

IRS Issues Final Prevailing Wage and Apprenticeship Regulations for Clean Energy Tax Credits

The Background: The Inflation Reduction Act ("IRA") created or enhanced various tax credits for qualifying renewable energy projects. However, a taxpayer loses 80% of otherwise-available IRA credits unless prevailing wage...more

Proposed Treasury Regulations Provide Guidance on New Clean Electricity Production and Investment Tax Credits

The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Administration Finalizes Regulations on Clean Energy Tax Credit Transfers

The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more

Proposed Guidance Clarifies "Foreign Entity of Concern" Restrictions for Clean Vehicle Credit

New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...more

Proposed IRS Regulations on Tax Credits for Renewable-Energy Investments Include Wage and Apprenticeship Requirements

In Short - The Background: The Inflation Reduction Act provides for robust tax incentives on qualifying renewable-energy construction projects. In order to claim the full amount of such tax credits on qualifying projects,...more

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Guidance Clarifies Requirements for Energy Tax Credits' Domestic Content Bonus

The U.S. Department of the Treasury has issued interim guidance outlining forthcoming proposed regulations regarding the domestic content bonus credit available to clean energy projects under the Inflation Reduction Act of...more

Tax Credits for Sale: Opportunities for Financing Renewable Energy and Carbon Reduction Projects Under the Inflation Reduction Act

The Inflation Reduction Act gives taxpayers two options for monetizing the Internal Revenue Code's energy-related tax credits—a "direct pay" election and the ability to sell credits to third parties for cash. These options...more

Inflation Reduction Act: Impact on Electric Vehicle and Transportation Industries

The Inflation Reduction Act of 2022 (the "Act"), signed into law by President Biden this month, offers new or expanded tax incentives for buying electric vehicles ("EVs") and using or producing certain environmentally...more

The Inflation Reduction Act: Impact on Renewable Energy

The Inflation Reduction Act (the "Act"), signed into law by President Biden on August 16, 2022, will significantly impact clean energy. This White Paper contains a summary of the provisions most relevant to the renewable...more

Inflation Reduction Act of 2022: Corporate Minimum Tax

In Short - The Situation: On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 into law. The Act establishes a new 15% corporate minimum tax (the "CMT") on large U.S. corporations (generally...more

Inflation Reduction Act Expands the Carbon Capture and Sequestration Tax Credit

The Act breathes new life into Section 45Q, the federal carbon capture tax credit, available to taxpayers capturing and sequestering qualifying carbon dioxide and other carbon oxides and claimed over a 12-year period. The...more

2022 & Beyond: Continued Challenges in the Automotive Supply Chain

While our inboxes are flooded on a daily basis with news about how the pandemic has created supply chain and commodities issues, global organizations must think about more than just near-term issues. Although the pandemic...more

Proposed Regulations Address Deductibility of Business Interest Expense - Important guidance issued on the new 30 percent...

On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more

Proposed Treasury Regulations Permit Foreign Subsidiary Credit Support for U.S. Multinational Financings

The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign corporate subsidiary ("CFC") for deemed dividends triggered when the CFC provides...more

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