News & Analysis as of

Infrastructure Investment and Jobs Act (IIJA) U.S. Treasury

Miller Canfield

US Issues Final Regulations on FEOC Exclusions from Clean Vehicle Credit

Miller Canfield on

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

Cooley LLP

Transitional Tax Reporting Guidance for Business Transactions Involving Digital Assets

Cooley LLP on

In Announcement 2024-4, the IRS and the US Department of the Treasury stated that, until regulations are issued, taxpayers will not be required to treat digital assets received in the course of their trade or business as cash...more

Paul Hastings LLP

Treasury Issues Proposed Regulations on the Section 30D Clean Vehicle Tax Credit’s Foreign Entity of Concern Rules

Paul Hastings LLP on

The Inflation Reduction Act of 2022 brought about modifications to the clean vehicle tax credit available under Section 30D of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Clean Vehicle...more

Eversheds Sutherland (US) LLP

DOE, Treasury and IRS issue guidance regarding foreign entity of concern for section 30D tax credit eligibility

On December 4, 2023, the Department of Energy (DOE), Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published related proposed guidance on the eligibility of an electric vehicle for the section...more

Miller Canfield

US Issues Proposed Regulations on FEOC Exclusions from Clean Vehicle Credit

Miller Canfield on

On December 4, 2023, the U.S. Department of the Treasury and Internal Revenue Service (IRS) published long-awaited proposed regulations (Notice of Proposed Rulemaking) regarding the Foreign Entity of Concern (FEOC) exclusions...more

Troutman Pepper

Guidance Suggests U.S. Clean Vehicle Subsidies Require Disengagement From China Supply Chains

Troutman Pepper on

On December 1, the U.S. Department of Energy (DOE) released long-awaited proposed guidance defining “foreign entity of concern” (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Simultaneously, the U.S....more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Proposed Regulations and Revenue Procedure on the Clean Vehicle Tax Credits under Section 30D of...

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

Faegre Drinker Biddle & Reath LLP

Long-Awaited EV Guidance Proposes New Restrictions on Foreign Entities of Concern and Further Clarifications

DOE Proposed Guidance - On December 1, the Biden administration’s Department of Energy released its latest proposed guidance related to the electric vehicle incentive expanded through the Inflation Reduction Act. DOE’s...more

Holland & Knight LLP

A Look at Foreign Entities of Concern and the Section 30D Clean Vehicle Tax Credit

Holland & Knight LLP on

The U.S. Department of Energy (DOE) recently released proposed guidance defining "foreign entity of concern" (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Among other reasons, this proposed guidance is...more

Cooley LLP

Treasury Department Issues Proposed Regulations for Brokers of ‘Digital Assets’

Cooley LLP on

On August 25, 2023, the US Department of the Treasury issued proposed regulations that would impose new information reporting requirements for brokers that facilitate certain transactions involving “digital assets” – if...more

Paul Hastings LLP

Digital Asset Payment Processors Will be Required to Report Consumers’ Digital Asset Transactions

Paul Hastings LLP on

The Internal Revenue Service and Treasury Department have issued long-awaited Proposed Regulations for parties that will be required to report transactions involving digital assets. These newly identified parties will need to...more

BakerHostetler

Digital Asset Broker Regulations Target DeFi Platforms and Payment Processors

BakerHostetler on

The Internal Revenue Service (IRS) and the Department of the Treasury issued a 282 page notice of proposed rulemaking regarding digital assets and broker reporting on Aug. 26 (the Proposed Regulations), nearly two years after...more

Lowenstein Sandler LLP

Proposed Regulations Would Impose New Reporting Requirements on Transactions Involving Cryptocurrency and Other Digital Assets

Lowenstein Sandler LLP on

In response to a provision in the 2021 Infrastructure Investment and Jobs Act, the Department of the Treasury and the Internal Revenue Service (IRS) have issued proposed regulations that would impose new tax reporting...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Regulations Regarding Reporting Requirements for Digital Asset and Cryptocurrency Transactions

On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released proposed regulations regarding information reporting, determination of amount realized and basis, and backup...more

Fenwick & West LLP

IRS Releases Proposed Regulations on Digital Asset Transaction Reporting

Fenwick & West LLP on

On Friday, August 25, 2023, the U.S. Treasury Department (Treasury) released proposed regulations interpreting the broker reporting rules for digital assets that were part of the 2021 Infrastructure Investment and Jobs Act...more

Foley & Lardner LLP

Qualifying Qualified Broadband Projects: NABL’s Request for Guidance to Clarify Qualified Broadband Project Provisions

Foley & Lardner LLP on

The Infrastructure Investment and Jobs Act (“IIJA”) has provisions to encourage investment in high-speed broadband projects, but as written, the legislation leaves open for interpretation several provisions. Guidance or...more

Cozen O'Connor

Cozen Currents: Biden Needs to Draw a Crowd

Cozen O'Connor on

The Cozen Lens- To achieve his goals of boosting clean energy and reinvigorating domestic manufacturing, President Biden aims to leverage funding from the private sector to implement his three major legislative achievements:...more

Morgan Lewis

Digital Asset Brokers: Proceed with Caution

Morgan Lewis on

The IRS has effectively delayed the implementation of the new digital asset broker rules under Internal Revenue Code Sections 6045 and 6045A. The US Treasury Department (Treasury) and Internal Revenue Service (IRS) recently...more

Paul Hastings LLP

IRS Delays Reporting Requirements on Digital Assets for “Brokers” But Not Businesses that Receive Digital Assets in Excess of...

Paul Hastings LLP on

The Infrastructure Investment and Jobs Act (H.R. 3684), (“Infrastructure Law”) was passed in 2021, and contained two provisions that target the reporting of digital assets....more

Foley & Lardner LLP

Top Legal Issues Facing the Automotive Industry in 2022

Foley & Lardner LLP on

In 2022, automotive suppliers face many of the same issues that have bedeviled the industry throughout 2021, as well as a host of all-new challenges. Unfortunately, as with many aspects of pre-pandemic life, the relative...more

Morrison & Foerster LLP

Treasury Suggests Limiting Definition of Digital Asset Broker

Recent correspondence between a group of U.S. Senators and the Department of the Treasury appears to have eased the significant concerns expressed by the digital asset sector regarding the scope of the new broker reporting...more

Dechert LLP

U.S. Treasury Signals that Cryptocurrency Miners & Stakers Will Not Be Subject to Broker Information Reporting Tax Requirements

Dechert LLP on

On February 11, 2022, in a letter addressed to certain U.S. Senators, the U.S. Department of the Treasury indicated that cryptocurrency miners, cryptocurrency stakers or related hardware or software providers would not be...more

Bracewell LLP

Certain CCUS Projects Now Eligible for Financing with Tax-Exempt Bonds

Bracewell LLP on

Tax-exempt bonds can now be added to the list of ways in which carbon capture, utilization and storage (“CCUS”) projects can be financed. Specifically, the Infrastructure Investment and Jobs Act (the “Act”) amends section...more

Morrison & Foerster LLP

New Cryptocurrency Reporting Requirements

Morrison & Foerster LLP on

Through its recent passage of the Infrastructure Investment and Jobs Act (the “Act”), Congress resolved an open question regarding the extent to which cryptocurrency transactions should be subject to information reporting...more

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