News & Analysis as of

Manufacturers Internal Revenue Service Proposed Regulation

Troutman Pepper

Treasury and IRS Issue Additional Domestic Content Guidance Under IRA and New Elective Safe Harbor

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On May 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-41, which modifies Notice 2023-38 (Prior Guidance) by expanding the list of Applicable Projects (defined below) to...more

Vinson & Elkins LLP

Treasury Issues Proposed Regulations on 45X Advanced Manufacturing Production Credit

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On December 14, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) providing additional guidance to taxpayers on the advanced...more

Holland & Knight LLP

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

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The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more

Foley & Lardner LLP

Electrified Industrial Policy: IRS Proposed Regulations on Section 30D EV Tax Credits & EV Manufacturing Grants

Foley & Lardner LLP on

The Inflation Reduction Act of 2022 (the “IRA”) and the Infrastructure Investment and Jobs Act of 2021 (the “IIJA”) set in motion an ongoing series of changes that are aimed at transforming, among other things, the automotive...more

Troutman Pepper

Updated IRS Guidance on Critical Minerals and Battery Components Has Demonstrable, Ongoing Implications for Domestic and Foreign...

Troutman Pepper on

Introduction - On March 31, the Internal Revenue Service (IRS) issued highly anticipated proposed regulations on electric vehicle (EV) tax credits. Driven by an ambitious climate agenda, the Biden administration has...more

Holland & Knight LLP

Treasury Department Issues 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 to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

Foley & Lardner LLP

Attention Taxpayers: New IRS Rules May Deem Debt to Be Stock

Foley & Lardner LLP on

In April, the IRS proposed rules that would treat debt between related corporations as stock for U.S. tax purposes. These rules would apply to all corporations (including regular C corporations, S corporations, foreign...more

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