On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations”) concerning the election to transfer certain tax credits...more
On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more
5/2/2024
/ C-Corporation ,
FIRPTA ,
Foreign Ownership ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Pension Funds ,
Public Entities ,
Qualified Investment Funds (QIFs) ,
REIT ,
U.S. Treasury
The Inflation Reduction Act of 2022 (the “IRA”), which was signed into law on Tuesday, August 16, 2022, includes an investment of over $369 billion in energy security and climate change. There has been a lot of discussion...more