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Energy Sector Internal Revenue Service Proposed Regulation

ASKramer Law

Energy Tax Credits for a New World Part II: Production Tax Credits and Investment Tax Credits: The Old and the New

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What is a Production Tax Credit (PTC)? A Production Tax Credit (PTC) is a per kilowatt-hour (kWh) tax credit for electricity generated by solar and other qualifying clean technologies for the first 10 years of a system’s...more

BakerHostetler

Proposed Regulations - Clean Electricity Production and Investment Credits (45Y and 48E)

BakerHostetler on

The IRS and Treasury on June 3 issued proposed regulations under Sections 45Y and 48E (proposed regulations), which address clean electricity production and investment tax credits, respectively, that generally replace...more

Holland & Knight LLP

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

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The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

A&O Shearman

Takeaways from Treasury's proposed regulations on U.S. tax credits for clean hydrogen production

A&O Shearman on

The U.S. Treasury Department (Treasury) and the Internal Revenue Service (the IRS) issued proposed regulations on December 22, 2023, providing initial guidance on the clean hydrogen tax credit under section 45V (the 45V...more

McDermott Will & Emery

IRS Leans “Green”: Much-Awaited Section 45V Guidance Creates New Opportunities for Hydrogen Markets

On December 22, 2023, the Internal Revenue Service (IRS) published long-awaited proposed regulations for hydrogen tax credits under Internal Revenue Code (Code) Sections 45V and 48. The proposed regulations address many...more

Eversheds Sutherland (US) LLP

Diving into the section 48 investment tax credit proposed regulations

On November 17, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) relating to eligible energy property that qualifies for the section 48...more

Holland & Knight LLP

An In-Depth Look at Section 45X Proposed Regulations

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The U.S. Department of the Treasury and IRS on Dec. 14, 2023, released Proposed Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. (See Holland& Knight's previous...more

K&L Gates LLP

Recent Treasury Proposed Regulations' Application to Qualified Offshore Wind Properties

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On 17 November 2023, the US Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) updating rules for the investment tax credit (ITC) under Code1...more

K&L Gates LLP

Highlights of Section 48 Investment Tax Credit Proposed Regulations

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On 17 November 2023, the US Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) updating rules for the investment tax credit (ITC) under...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Long-Awaited Proposed Regulations on Section 48 Investment Tax Credits

On November 17, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) regarding the investment tax credit (ITC) under...more

McGuireWoods LLP

IRS Refreshes and Codifies Energy Property Tax Credit Guidance in Proposed Section 48 Regulations

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On Nov. 17, 2023, the IRS and Treasury Department released a series of proposed regulations for the Section 48 investment tax credit (ITC) that the energy market has anticipated for nearly a decade. These proposed rules...more

Eversheds Sutherland (US) LLP

Key proposed regulations issued regarding prevailing wage and registered apprenticeship requirements

On August 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) on the clean energy prevailing wage and apprenticeship (PWA) requirements...more

A&O Shearman

Navigating Treasury's proposed regulations on prevailing wage and apprenticeship for clean energy projects

A&O Shearman on

The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations on August 29, 2023 for prevailing wage and apprenticeship (“PWA”) requirements applicable to clean energy projects...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Regulations Regarding the Prevailing Wage and Apprenticeship Requirements

On August 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of proposed rulemaking and accompanying frequently asked questions (Proposed Regulations) regarding the...more

Vinson & Elkins LLP

Treasury Issues Proposed Regulations for IRA Labor Requirements

Vinson & Elkins LLP on

On August 29, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) providing proposed rules governing the prevailing wage and...more

Eversheds Sutherland (US) LLP

Treasury and IRS release proposed regulations on transferability of IRA renewable energy credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more

Holland & Knight LLP

Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

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The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more

BakerHostetler

Overview of the Proposed Regulations Addressing Direct Pay

BakerHostetler on

As covered in our prior alerts, the Inflation Reduction Act[1] (IRA) modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable...more

Eversheds Sutherland (US) LLP

Treasury and IRS release domestic content guidance for renewable energy tax credits

On May 12, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2023-38 to provide guidance on the domestic content requirements under IRC sections 45, 45Y, 48, and 48E....more

Holland & Knight LLP

Eyes on Energy Tax Update: First Quarter 2023

Holland & Knight LLP on

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. ...more

Foley & Lardner LLP

IRS Releases Guidance on Energy Community Credit Adder

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On April 4, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) released Notice 2023-29 (the “Notice”) providing a high-level overview of the rules they intend to include in...more

McDermott Will & Emery

Six Takeaways: Utilization and Structuring For Section 45Q Carbon Capture Credits

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The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more

McDermott Will & Emery

[Webinar] Utilization and Structuring For Section 45Q Carbon Capture Credits - June 11th, 12:30 pm EST

The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more

Bracewell LLP

Straight from the Source: Proposed Regulations Seek to Implement TCJA Changes to Source of Income Rules, Altering Treatment for...

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The source of income is a critical component of U.S. tax rules for both U.S. taxpayers operating internationally (namely, with respect to foreign tax credit planning) and foreign persons with investment or other activity in...more

Bracewell LLP

Bracewell Tax Report - September 2018

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

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