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DOE, Treasury and IRS issue guidance regarding foreign entity of concern for section 30D tax credit eligibility | Eversheds Sutherland (US) LLP

On December 4, 2023, the Department of Energy (DOE), Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published related proposed guidance on the eligibility...
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Diving into the section 48 investment tax credit proposed regulations | Eversheds Sutherland (US) LLP

On November 17, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) relating to eligible energy...
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Another CAMT crumble: IRS releases Notice 2024-10 addressing potential double counting from CFC dividends | Eversheds Sutherland (US) LLP

On December 15, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Notice 2024-10 (Notice) addressing the potential double counting of income...
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An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance | Eversheds Sutherland (US) LLP

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of...
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Directions regarding Direct Pay - Proposed Regulations Released on Elective Payment for Inflation Reduction Act Renewable Energy Credits | Eversheds Sutherland (US) LLP

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the...
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