With the Trump administration and a Republican-controlled Congress now in office, significant changes to the U.S. economic landscape and tax policy are expected. Indeed, legislation to change tax policy and to implement...more
3/12/2025
/ Budget Cuts ,
Corporate Taxes ,
Executive Orders ,
Federal Budget ,
Legislative Agendas ,
SALT ,
State and Local Government ,
Tariffs ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Trump Administration
The saga of the CTA continues. Adopted in January 2021, the Corporate Transparency Act (CTA) is intended to assist in identifying beneficial ownership and control of entities operating in the United States in order to...more
1/28/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Business Entities ,
Constitutional Challenges ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
SCOTUS
On January 10, 2025, the Internal Revenue Service (IRS) issued Notice 2025-10 and Notice 2025-11. Notice 2025-10 summarizes proposed regulations (Proposed Regulations) that Treasury and the IRS plan to issue with respect to...more
On January 7, 2025, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations [TD 10024] (Final Regulations) providing guidance on the Clean Electricity Production Tax Credit...more
The Internal Revenue Service (IRS) has provided broad tax relief to taxpayers in Los Angeles County impacted by the recent winds and wildfires.
Other counties may be added later....more
1/17/2025
/ Adjusted Gross Income ,
California ,
Excise Tax ,
FEMA ,
Filing Deadlines ,
Health Savings Accounts ,
Individual Retirement Account (IRA) ,
IRS ,
Payroll Taxes ,
Penalties ,
Property Owners ,
Property Tax ,
State Taxes ,
Tax Deductions ,
Tax Incentives ,
Tax Relief ,
Tax Returns ,
Wildfires
The final regulations retain the general framework of the proposed regulations, with some important modifications based upon comments from industry members.
The acquisition and retirement of energy attribute certificates...more
1/9/2025
/ Carbon Capture and Sequestration ,
Clean Energy ,
Department of Energy (DOE) ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
IRS ,
Methane ,
Natural Gas ,
Nuclear Power ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
The Fifth Circuit Court of Appeals has stayed the preliminary injunction issued on December 3, 2024, in the Texas Top Cop Shop case by a U.S. District Court. As a result, the original beneficial ownership reporting...more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
Under the final regulations, taxpayers are permitted to produce eligible components using recycled materials.
Components which are sold and then later become defective will not be considered defective components for...more
Beneficial Ownership Reports are filed electronically through the Financial Crimes Enforcement Network.
Individuals who need to be reported as beneficial owners or company applicants should apply for a FinCEN ID number....more
The proposed regulations update outdated references and information under the current regulations, including references to temporary regulations, IRS officials, offices and addresses.
The proposed regulations conform with...more
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
The application cycle for Treasury to award this round of credits will soon open, providing applicants an opportunity to receive significant funding for clean energy, industrial decarbonization and critical materials...more
5/6/2024
/ Clean Energy ,
Department of Energy (DOE) ,
Energy Sector ,
Greenhouse Gas Emissions ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Nuclear Power ,
Solar Energy ,
Tax Credits ,
U.S. Treasury ,
Wind Power
The IRS has increased funding for collection and enforcement, with a stated focus on high income non-filers and digital assets (among other areas).
The DOJ has also emphasized a focus on digital assets, and the Department...more
With millions of people already using artificial intelligence (AI) to perform a variety of personal tasks and companies integrating large language model (LLM) services for professional use, concerns over the frequency with...more
A trust structure, commonly used for estate planning, can be problematic in certain civil law jurisdictions, such as those in many European countries.
Recent acts enacted in Wyoming and New Hampshire allow for the...more
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 Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a rule that extends the deadline from 30 days to 90 days for reporting companies created or registered in 2024 to file initial beneficial...more
When the Corporate Transparency Act (CTA) goes into effect in January 2024, millions of companies will face new beneficial ownership reporting obligations.
The Financial Crimes Enforcement Network has proposed allowing...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
Under the IRA, select renewable energy credits are transferrable, including to individuals and pass-through entities.
The transferees of these credits are subject to the passive activity rules of Section 469 of the...more
Arguments presented by Coinbase in its answer to SEC charges would, if accepted, potentially deprive the SEC of its most effective tool in regulating digital assets.
The SEC alleges in a Complaint in SDNY that Coinbase...more
7/6/2023
/ Coinbase ,
Contested Proceedings ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Howey ,
New Legislation ,
Regulatory Authority ,
SCOTUS ,
Securities Act ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Securities Regulation