The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more
8/30/2024
/ Chevron Deference ,
Corporate Counsel ,
Foreign Subsidiaries ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
SCOTUS ,
Tax Court ,
Tax Liability ,
U.S. Treasury
The U.S. Supreme Court has affirmed the Ninth Circuit's decision in Moore v. United States, upholding the constitutionality of the mandatory repatriation tax enacted in 2017....more
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
7/5/2024
/ Apprenticeships ,
Clean Energy ,
Department of Labor (DOL) ,
Employer Liability Issues ,
Energy Projects ,
Inflation Reduction Act (IRA) ,
IRS ,
Prevailing Wages ,
Renewable Energy ,
Tax Credits ,
Wage and Hour
The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more
6/3/2024
/ Clean Energy ,
Energy Projects ,
Greenhouse Gas Emissions ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Oil & Gas ,
Production Tax Credit ,
Proposed Regulation ,
U.S. Treasury ,
Zero Emission Credits
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
5/15/2024
/ Automotive Industry ,
Clean Car Standards ,
Clean Energy ,
Department of Energy (DOE) ,
Due Diligence ,
Electric Vehicles ,
Federal Taxes ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
IRS ,
Proposed Guidance ,
Supply Chain ,
Tax Credits ,
U.S. Treasury
The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more
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
1/3/2024
/ Automotive Industry ,
Clean Car Standards ,
Clean Energy ,
Department of Energy (DOE) ,
Electric Vehicles ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
IRS ,
Motor Vehicles ,
Proposed Guidance ,
Tax Credits ,
U.S. Treasury
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
10/11/2023
/ Apprenticeships ,
Clean Energy ,
Comment Period ,
Construction Workers ,
Davis-Bacon Act ,
Department of Labor (DOL) ,
Inflation Reduction Act (IRA) ,
IRS ,
NLRA ,
Popular ,
Prevailing Wages ,
Proposed Regulation ,
Recordkeeping Requirements ,
Renewable Energy ,
Renewable Energy Incentives ,
Tax Credits ,
Wage and Hour
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
Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform.
On August 1, 2018, proposed...more