News & Analysis as of

Partnerships Tax Credits U.S. Treasury

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

Holland & Knight LLP

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

Holland & Knight LLP on

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

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...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

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

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 § 6417 an election that allows applicable entities...more

Skadden, Arps, Slate, Meagher & Flom LLP

Observations on Notice 2023-80: The Treasury Department and IRS’ Preliminary Guidance on the Interaction of Foreign Tax Credit and...

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more

Paul Hastings LLP

Treasury and IRS Provide Guidance on Energy Tax Credit Direct Payment Elections

Paul Hastings LLP on

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 elect to receive a direct payment in lieu of certain energy...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Akin Gump Strauss Hauer & Feld LLP

IRS Revises Historic Tax Credit Revenue Procedure

Revenue Procedure 2014-12 provides a safe harbor for historic tax credit (i.e., the Section 47 rehabilitation tax credit) partnership transactions. On January 8, the IRS issued a revised version of it that provides a...more

9 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide