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The U.S. Internal Revenue Service (IRS) and the U.S. Treasury
Department ("Treasury") have issued final regulations (T.D. 9944) (the "Final Regulations")
providing additional guidance on several aspects of the income tax
credit for the capture of qualified carbon oxide (CO) under section
45Q of the Internal Revenue Code of 1986, as amended (the
"Code").
1 By largely adopting the proposed
regulations released on May 28, 2020 (REG -112339-19) (the "Proposed
Regulations"), discussed in our client alert dated June 22, 2020, with
certain helpful modifications, the Final Regulations aim to