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Final Rules Tax Credits

Holland & Knight LLP

Highlights of Final Regulations Under Section 45X Advanced Manufacturing Tax Credit

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The U.S. Department of the Treasury and IRS on Oct. 28, 2024, published final regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (Final Regulations)....more

Vinson & Elkins LLP

Taxpayers Find Helpful Clarity in Final 45X Regulations, as Critical Minerals and Electrode Active Material Producers Strike Gold

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On October 24, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Final 45X Regulations”) regarding the Advanced Manufacturing Production Tax...more

Holland & Knight LLP

Treasury Department Issues Final Section 48D Guidance on CHIPS Act Semiconductor Tax Incentive

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The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code (Code) to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the U.S. The credit is equal to...more

Holland & Knight LLP

Treasury Department, IRS Release Section 45X Advanced Manufacturing Production Credit Final Regulations

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The U.S. Department of the Treasury and IRS on Oct. 24, 2024, released Final Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. The Final Regulations are effective 60...more

Bradley Arant Boult Cummings LLP

Tipped Out? 5th Circuit Negates DOL Tip Credit Rule

How the FLSA “tip credit” is applied has been pushed and pulled numerous times over the last two decades. In the latest volley, the Fifth Circuit entered an order on August 23, 2024, vacating the Department of Labor’s 2021...more

Mayer Brown

Final Regulations Issued on Prevailing Wage and Apprenticeship Requirements under the Inflation Reduction Act

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On June 18, 2024, the US Internal Revenue Service (“IRS”) and Department of the Treasury (“Treasury”) issued final regulations (“Final Regulations”) establishing rules for taxpayers intending to satisfy the prevailing wage...more

Mayer Brown

Final Guidance Issued on “Foreign Entity of Concern” Criteria

Mayer Brown on

On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

Latham & Watkins LLP

Final Regulations Issued on Domestically Controlled REIT Determinations and Energy Credit Transfers

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Two sets of recently finalized regulations provide guidance for REITs. Key Points: - Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more

Holland & Knight LLP

Treasury Department, IRS Issue Final Rules Under Clean Vehicle Tax Credits

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The Federal Register on May 6, 2024, published final regulations issued by the U.S. Department of the Treasury and IRS under the clean vehicle tax credits found at Sections 25E (previously owned clean vehicles) and 30D (clean...more

Miller Canfield

US Issues Final Regulations on FEOC Exclusions from Clean Vehicle Credit

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On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations on the Electric Vehicle Credits Under Section 30D of the Internal Revenue Code

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

Mayer Brown

REITs’ Clean Energy Tax Credits Transfer Options Under IRA Clarified in Final Regulations

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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

Womble Bond Dickinson

IRS Publishes Final Regulations for Transfer of Certain Credits

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The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code (the “Code”) to allow taxpayers to sell certain Federal income tax credits....more

Holland & Knight LLP

Treasury Department Releases Final Regulations on Clean Vehicle Credits Under Sections 25E, 30D

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The U.S. Department of the Treasury and IRS released final regulations on May 3, 2024, on Clean Vehicle Credits under Sections 25E and 30D of the Internal Revenue Code. Among other areas, the regulations provide final...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations Regarding the Transferability of Tax Credits Under Section 6418 of the...

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

BakerHostetler

Monetizing Renewable Credits Part II - Final Regulations on Transfers of Renewable Credits

BakerHostetler on

As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more

Holland & Knight LLP

Treasury Department, IRS Release Final Regulations on Direct Pay Under CHIPS Act Section 48D

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The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the production of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more

Woodruff Sawyer

2024 Compliance Hot Topics

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Congratulations to everyone for successfully safely navigating your health plans out of the pandemic crisis. We will review some of the key 2024 compliance hot topics you should know about in this annual benefits legislative...more

Holland & Knight LLP

Inflation Reduction Act Direct Pay Rules Finalized

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The U.S. Department of the Treasury and IRS released final regulations under Section 6417 of the Internal Revenue Code, as enacted by the Inflation Reduction Act (IRA). Section 6417 allows certain taxpayers to elect to...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

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The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may make an elective payment, which will treat certain eligible...more

Schwabe, Williamson & Wyatt PC

Department of Treasury Issues Final Regulations Regarding Elective Pay Program ‎

The final regulations are effective on May 10, 2024. ‎ Last week, the Department of the Treasury issued final regulations that address the Elective Pay program (also called direct pay), predominantly under Internal Revenue...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed and Final Regulations on Direct Pay Elections

On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more

Troutman Pepper

IRS Issues Final Regulations on Direct Pay

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On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the...more

Paul Hastings LLP

SEC Issues Final Rule on Climate Disclosures

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In an open meeting on Wednesday, March 6, 2024, the Securities and Exchange Commission (“SEC”) approved in a 3-2 vote a Final Rule on climate disclosures that will “require registrants to provide certain climate-related...more

Holland & Knight LLP

Treasury Department and IRS Release Final Regulations on the Direct Payment of Tax Credits

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The U.S. Department of the Treasury and IRS on March 5, 2024, released final regulations regarding the direct payment of tax credits under Section 6417 of the Internal Revenue Code (Elective Payment of Applicable Credits)....more

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