Eversheds Sutherland Tax Reform Law Blog
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Legal Alert: Inflation Reduction Act of 2022 signed into law – A summary of the energy tax provisions

The Inflation Reduction Act of 2022 (the Act) was signed into law on August 16, 2022, and includes about $370 billon for American energy security and climate change. Those changes include very substantial extensions, expansions and modifications of the tax credits for renewable and alternative energy development. In one of the best-kept secrets in Washington, Senators Manchin...

Legal Alert: Inflation Reduction Act of 2022 – The energy tax provisions you need to know about

The Inflation Reduction Act of 2022 (the Act) runs 725 pages and includes numerous energy tax provisions aimed at enhancing US. energy security. The Act, if enacted, would extend and expand the renewable and alternative energy tax credits, shift to technology neutral credits in 2025, provide for US energy component manufacturing credits and modify the rules for electric vehicle tax...

Legal Alert: A welcome clean energy surprise – Inflation Reduction Act includes energy tax extensions and expansions

In a surprising turn of events, late on July 27, 2022, Senators Manchin (D-WV) and Schumer (D-NY) released the Inflation Reduction Act of 2022. The Act, which runs 725 pages, includes numerous energy tax provisions aimed at enhancing US energy security. Tax pay-fors in the bill include a corporate minimum tax and an increase in the tax rate on carried interest. A...

Legal Alert: IRS provides additional guidance on cost of removal, salvage and normalization

In PLR 202141001 (July 15, 2021) the IRS expanded upon the guidance it provided in PLR 202033002 (Aug. 14, 2020) regarding the proper ratemaking treatment of cost of removal (COR) and salvage under the normalization rules. As explained in our alert, the IRS: Reaffirmed that COR is not subject to the normalization rules, but salvage must be normalized. The computation of the reversal of...

Legal Alert: IRS extends continuity safe harbor for renewable energy projects

On June 29, 2021, the IRS issued Notice 2021-41, which provides a further extension of the continuity safe harbor and revises the “facts and circumstances” rules:- For PTC and ITC-eligible projects for which construction began in calendar years 2016 through 2019, the continuity safe harbor is extended to six years.- For PTC and ITC-eligible projects for which construction began in...

Legal Alert: FY 2022 Green Book goes big for green energy

On May 28, 2021, Treasury released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals, more commonly referred to as the Green Book. The issuance of the Green Book provides further detail on the White House’s American Jobs Plan, one of the major proposals in the development of an infrastructure bill. The Green Book’s release comes as Congress works...