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Treasury and IRS Issue Updated Domestic Content Guidance Under IRA and First Updated Elective Safe Harbor

On January 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-08 (Notice), which provides an updated safe harbor (First Updated Elective Safe Harbor) that modifies and otherwise...more

Treasury and IRS Issue Final Regulations on Clean Electricity Production and Investment Tax Credits

On January 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published final regulations providing further guidance on the clean electricity production credit under Section 45Y and the clean...more

IRS Issues Final Regulations on Clean Hydrogen Tax Credits

The IRS and the Treasury Department issued final regulations on January 3 (Final Regulations), providing guidance on the clean hydrogen production tax credit under Section 45V (Hydrogen PTC) and the investment tax credit...more

IRS Releases Final Direct Pay Energy Tax Credit Regulations

On March 5, 2024, the Internal Revenue Service and the Treasury Department issued final Treasury Regulations (the “Final Regulations”) updating and finalizing previously published proposed Treasury Regulations relating to the...more

Is Arbitrage a Thing Again?

What is arbitrage? Generally, arbitrage is the simultaneous buying and selling of securities in different markets to exploit the difference in pricing. Specific to the tax-exempt bond market, arbitrage arises when a...more

Treasury and IRS Release Favorable Final Regulations on University Excise Tax

On September 18, 2020, the United States Department of the Treasury (“Treasury”) and the Internal Revenue IRS (the “IRS”) issued final regulations (the “Final Regulations”) under section 4968 of the Internal Revenue Code of...more

In Response to the COVID-19 Pandemic, the IRS Releases Temporary Guidance to State and Local Issuers of Tax-Exempt Bonds

On May 4, 2020 the Internal Revenue Service (IRS) released Notice 2020-21 (Public Hearing Notice) and Notice 2020-25 (Reissuance Notice). These Notices provide limited, temporary relief to issuers of tax-exempt bonds in two...more

Opportunity Zones Program: Helping Clients Understand New Tax Incentives Program for Long-Term Investments in...

The Tax Cuts and Jobs Act added the Opportunity Zones concept as Section 1400Z to the Internal Revenue Code, which is designed to incentivize private investment in low income areas. That section of the Code allows the...more

Summary of the Impact of the Proposed Tax Cuts and Jobs Act on State and Local Bonds

On November 2, 2017, the Tax Cuts and Jobs Act (the “Bill”) was introduced in the United States House of Representatives and is currently before the House Ways and Means Committee. The Bill proposes both direct and indirect...more

The Effective Date of the New Issue Price Regulations is Near

On December 9, 2016, the United States Treasury Department published regulations (the “Issue Price Regulations”) setting forth new rules for the determination of the issue price of a tax-exempt bond issue. The Issue Price...more

IRS Releases New Management Contract Rules

On January 17, 2017, the Internal Revenue Service (IRS) released Revenue Procedure 2017-13 (2017-13). This revenue procedure modified, amplified, and superseded Revenue Procedure 2016-44 (2016-44), which was just issued last...more

IRS Releases New Management Contract Safe Harbors For Bond-Financed Property

On August 22, 2016, the Internal Revenue Service (IRS) released Revenue Procedure 2016-44 (2016-44) and then modified 2016-44 on September 2, 2016. This revenue procedure was a response from the IRS to a longstanding request...more

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