On December 2, 2024, the IRS published final regulations under Code[1] Sections 704 and 752 (pursuant to authority set forth in Code Section 7805(a)) relating to a partner’s share of recourse partnership liabilities, largely adopting the proposed regulations issued
The Treasury Department finalized regulations allowing for certain unincorporated organizations making investments in certain clean energy technologies to opt out of partnership treatment for federal income tax purposes by making an election under section 761(a) of the Internal Revenue Code
On October 28, 2024, the IRS published Final Regulations under Section 45X of the Internal Revenue Code of 1986 covering the “advanced manufacturing production credit” (the “45X Credit”). The 45X Credit was established by the Inflation Reduction Act of 2022 (“IRA”)
Interested and eligible manufacturers, developers, and sponsors looking to pursue new advanced energy project tax credits under Internal Revenue Code Sections 48C and 45X have been faced with an important question: Should you apply for the Advanced Energy Project Tax Credit
On June 14, 2023, the IRS released proposed regulations within Section 6418 Transfer of Certain Credits concerning the election under the Inflation Reduction Act of 2022 (IRA) to transfer certain energy tax credits. The industry has eagerly awaited these proposed
The month of May was a busy one for the IRS, as the agency has been hard at work releasing new guidance and rules regarding energy tax credits. In Notice 2023-38, the IRS provides detail on how the “domestic content”
