JD Supra

Treasury Department and IRS Issue Final Regulations Regarding the Clean Electricity Tax Credits Under Sections 45Y and 48E of the Internal Revenue Code

On January 7, 2025, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations [TD 10024] (Final Regulations) providing guidance on the Clean ...
JD Supra

Initial Guidance on Clean Fuel Production Credit Under IRC Section 45Z

On January 10, 2025, the Internal Revenue Service (IRS) issued Notice 2025-10 and Notice 2025-11. Notice 2025-10 summarizes proposed regulations (Proposed Regulations) that Treasury and the IRS plan ...
JD Supra

Tax Credit Transfers May Have Unexpected State Tax Consequences

One of the most celebrated features of the Inflation Reduction Act (“IRA”) is the ability to sell tax credits, including the Production Tax Credit (“PTC”) under Internal Revenue Code (“IRC”) § 45 and ...
JD Supra

Treasury and IRS Issue Final Regulations on the Credit for Production of Clean Hydrogen Under Section 45V of the Internal Revenue Code

The final regulations retain the general framework of the proposed regulations, with some important modifications based upon comments from industry members. The acquisition and retirement of energy ...
Wealth Management

Bridging Section409A And Gift Tax Valuations

Clients may be inclined to use a Section 409A valuation for gift tax purposes. After all, both valuations aim to determine ...