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Inflation Reduction Act
IRS and Treasury Department Release Initial Guidance for Labor Requirements Under Inflation Reduction Act
On November 30, 2022, the IRS and the Treasury Department published Notice 2022-61 (the Notice) in the Federal Register. The Notice provides guidance regarding the prevailing wage requirements (the Prevailing Wage Requirements) and the apprenticeship requirements (the Apprenticeship Requirements and...
PRG Pulse 2022 Post-Election Analysis
CONTENTS The Big Picture Congressional Overview White House Response Congressional Oversight The Key Issues Clean Energy & IRA Implementation Hydrogen Offshore Wind and Solar Carbon Capture & Storage Critical Minerals Oil & Gas Permitting Reform and Energy Infrastructure Energy...
General Overview of the Inflation Reduction Act of 2022
On Tuesday, August 16, President Biden signed the Inflation Reduction Act of 2022 (the Act ) into law, which includes material changes to various sections of the Internal Revenue Code of 1986, as amended (the Code ). The following is...
Taxpayers Get Answers on 45Q Questions With IRS Guidance
The Internal Revenue Service released helpful guidance in Revenue Ruling 2021-13, regarding the scope of carbon capture equipment and the requirement that a taxpayer own the carbon capture equipment to qualify for carbon sequestration credits under Internal Revenue Code Section...
IRS Provides Welcome Guidance on Code Section 45Q Credits in Revenue Ruling 2021-13
On July 1, 2021, the Internal Revenue Service (IRS) released Revenue Ruling 2021-13 (the Revenue Ruling), addressing the application of section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q) to carbon dioxide captured with carbon capture...
IRS Further Extends the Continuity Safe Harbor for Qualifying Solar and Wind Projects
On June 29, 2021, the IRS released Notice 2021-41 (the Notice) extending the length of the Continuity Safe Harbor (as defined below) for purposes of claiming the investment tax credit (ITC) or the production tax credit (PTC). Developers and investors...
The Future of Carbon Capture, Utilization and Storage Projects
Code Section 45Q and Proposed Amendments: Elizabeth McGinley Permitting Requirements for CCUS: Jeff Holmstead Land Rights for CCUS: JJ McAnelly and Austin Lee Contractual Arrangements for CCUS: Patrick Johnson CCUS Innovation and IP Due Diligence: Brad...
UAE and Israel Sign Tax Treaty
On Monday, 31 May 2021, the UAE and Israel signed a tax treaty in order to boost economic cooperation. It is expected that, following ratification later this year, the treaty will come into effect on 1 January 2022. The move...
Super Tax Exempt Limited Partners in Private Equity Funds: Impact on Solar Projects
Private equity and venture funds have been critical partners of the solar industry in recent years. Fund managers and the limited partners in their funds have sought broad exposure to solar assets—both utility scale and commercial and industrial scale—in search...
100 Days in 60 Minutes
The conversation will cover the Biden administration’s first 100 days and the challenges and opportunities that lie ahead. Tune in for topics including finance and tax, trade, technology and environmental justice. The event will begin with opening remarks from PRG...
Treasury Releases Final Regulations on 45Q Carbon Capture Credits
On January 6, 2021, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) under section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q), which allows a credit for...
2020 Incentive Stock Option & Employee Stock Purchase Plan Reporting
Now that 2021 is here, corporations should be aware of IRS reporting requirements regarding certain 2020 stock transactions with their employees. Section 6039 of the Internal Revenue Code of 1986, as amended (the “Code”), requires a corporation to report (i)...
Changes to Renewable and Carbon Capture Tax Credits under the Consolidated Appropriations Act, 2021
On December 22, 2020, the U.S. House and Senate approved the Consolidated Appropriations Act, 2021 (the 2021 Act) and, on December 27, 2020, President Trump signed the 2021 Act into law. The 2021 Act extends tax credits currently available for...
ESG Investing and Retirement Plans
Background As ESG (environmental, social and governance) investing recently has drawn the attention of governmental agencies that oversee the administration of qualified retirement plans and their trillions of dollars in assets. This is unsurprising given that focus and interest in...
IRS and Treasury Department Release Final Regulations Regarding Like-Kind Exchanges
On November 23, 2020, the IRS and Treasury Department released final regulations (the Final Regulations) under Section 1031 of the Internal Revenue Code of 1986, as amended (the Code). Prior to the Tax Cuts and Jobs Act of 2017 (the...