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Baker Botts L.L.P.

Proposed Regulations Regarding Section 48E Clean Electricity Low-Income Communities Bonus Credit Program

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On September 3, 2024, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) published proposed regulations relating to the Clean Electricity Low-Income Communities Bonus Credit Program (the...more

Pierce Atwood LLP

Will Treasury Use Energy Tax Credits to Assist PFAS-Impacted Communities?

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Proposed tax regulations to be released this year may clarify whether agricultural land contaminated with per- and polyfluoroalkyl substances (PFAS) qualify for a federal tax credit that would incentivize renewable energy...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Regulations for Low-Income Communities Bonus Program Under Section 48E

On August 30, 2024, 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 new clean electricity low-income...more

Holland & Knight LLP

Eyes on Energy Tax Update: Second Quarter 2024

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Eyes on Energy Tax Update is a regular publication of the Holland & Knight Renewable and Alternative Energy Tax Team that provides highlights of important developments. The Renewable and Alternative Energy Tax Team also...more

Vinson & Elkins LLP

Energy Makers Find Limited Answers in Bonus Tax Credit Guidance

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The domestic content bonus is one of the Inflation Reduction Act’s most powerful tax incentives, but so far is proving to be one of the most difficult to earn. The Treasury Department and IRS released Notice...more

Vinson & Elkins LLP

The Very Timely PWA Requirements Finalized

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On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage...more

Wilson Sonsini Goodrich & Rosati

Claiming Tech-Neutral Clean Electricity Production and Investment Tax Credits Under the Inflation Reduction Act

On May 29, 2024, the U.S. Department of the Treasury and the Internal Revenue Service released long anticipated Proposed Regulations regarding clean electricity production tax credits and clean electricity investment tax...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

Holland & Knight LLP

The Technology-Neutral Sections 45Y PTC and 48E ITC Are Coming

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The U.S. Department of the Treasury and IRS on May 29, 2024, issued proposed regulations under the new Internal Revenue Code (Code) Section 45Y Clean Electricity Production Tax Credit (PTC) and Section 48E Clean Electricity...more

Husch Blackwell LLP

New Treasury Guidance Silent on Biomass Electricity Credits

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On May 29, 2024, the U.S. Treasury Department and the Internal Revenue Service issued a notice of proposed rulemaking (“NPRM”) that includes guidance on two of the Inflation Reduction Act of 2022’s renewable electricity tax...more

Vinson & Elkins LLP

Treasury Releases Proposed Regulations on Tech-Neutral PTC and ITC

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On May 29, 2024, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations (REG-119283-23) (the “proposed regulations”) regarding the clean electricity production...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Treasury, Internal Revenue Service Issue Final Regulations for Transfer of Energy Credits

On April 25, 2024, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations regarding the transfer of energy tax credits under the Inflation Reduction Act of 2022 (IRA)....more

Cadwalader, Wickersham & Taft LLP

Final Rules on Energy Tax Credit Sales Confirm All Systems Go

The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits.  In our last update, we discussed how the emerging market for tax insurance may provide comfort to prospective...more

Pierce Atwood LLP

Energy Tax Credits – Final Regulations on Transferability and Guidance on Domestic Content

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The Treasury Department and IRS recently issued final regulations on the transfer of certain credits to implement the transferability provisions of the Inflation Reduction Act (IRA), which take effect on July 1, 2024....more

Stoel Rives LLP

Treasury Provides New Safe Harbor for Domestic Content Bonus Credit

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The U.S. Department of the Treasury (Treasury) today released Notice 2024-41, Domestic Content Bonus Credit Amounts under the Inflation Reduction Act of 2022: Expansion of Applicable Projects for Safe Harbor in Notice 2023-38...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

Troutman Pepper

IRS Issues Final Regulations on Tax Credit Transfers

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On April 25, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on tax credit transfers pursuant to Section 6418 of the Internal Revenue Code of 1986, as...more

BakerHostetler

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

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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

Foley & Lardner LLP

IRS Releases Final Tax Credit Sale Regulations

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Late last week, the Internal Revenue Service (“IRS”) and Department of the Treasury released final regulations relating to transfers of certain tax credits pursuant to Section 6418 of the Code (the “Code” and, such rules, the...more

Holland & Hart LLP

New Final Tax Credit Transferability Regulations Issued; Changes Minimal

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On April 25, 2024, the IRS and US Treasury Department issued the final regulations under Section 6418 of the Code, the provision that allows sales of certain tax credits, including credits for renewable energy production and...more

Vinson & Elkins LLP

Energy Credit Transferability Regulations Finalized

Vinson & Elkins LLP on

On April 25, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for...more

Holland & Knight LLP

Treasury Department and IRS Release Final Regulations on the Transfer of IRA Tax Credits

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As provided in the Inflation Reduction Act (IRA), eligible taxpayers may make a yearly election to transfer all (or any portion) of an eligible credit to an unrelated taxpayer under Section 6418 of the Internal Revenue Code,...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Propose Supplemental Notice Regarding Clean Hydrogen Production Tax Credit Regulations

On April 10, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of proposed rulemaking (the Supplemental Regulations) to supplement the Clean Hydrogen Production Tax...more

Mitchell, Williams, Selig, Gates & Woodyard,...

IRS Releases 2024 Procedural Guidance for Solar and Wind Projects in Low Income Communities

Last week the Department of Treasury and Internal Revenue Services (IRS) issued procedural guidance for the second year of the Low-Income Communities Bonus Credit Program under Section 48(e) of the Internal Revenue Code...more

Troutman Pepper

Treasury and IRS Release Further Guidance on Energy Community Enhancements Under IRA

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On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore...more

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