Adam Kobos
Portland
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Articles by Adam Kobos
Court Concludes on Cost Approach in Alta Wind , But It May Not Have Changed Status Quo
The U.S. Court of Federal Claims held that the cost approach, not the discounted cash flow approach, properly determines FMV of Section 1603 grant-eligible property for the Alta Wind projects. The court did not prohibit the income approach as a matter of law, finding the discounted cash flow method “not inherently defective” but insufficiently supported by evidence.
Court Issues Disappointing Decision in Alta Wind , But It May Not Have Changed Status Quo
The U.S. Court of Federal Claims held that the cost approach, not the discounted cash flow approach, properly determines FMV of Section 1603 grant-eligible property for the Alta Wind projects. The court did not prohibit the income approach as a matter of law, finding the discounted cash flow method “not inherently defective” but insufficiently supported by evidence.
IRS Issues Beginning of Construction Guidance in Response to July Executive Order | JD Supra
On August 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-42, which provides guidance on the beginning of construction requirement as it relates to the new credit termination dates for wind and solar projects enacted by the One Big Beautiful Bill Act (OBBBA).
Navigating the One Big Beautiful Bill Act: A Practical Guide | JD Supra
On July 4, 2025, H.R. 1 — the One Big Beautiful Bill Act (the OBBBA) was enacted into law. We discussed the version of the bill that passed in the House in May (the House bill) in our previous update. On July 1, the Senate passed the OBBBA, which was then passed in the House on July 3 and signed into law by the president on July 4.
Treasury and IRS Release Updated Guidance on Energy Communities (UPDATED) | JD Supra
On June 23, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-31. This notice includes lists of information that taxpayers may use to determine whether they meet certain requirements for energy communities under the Statistical Area Category or the Coal Closure Category, each as described in Notice 2023-29, Notice 2023-45, Notice 2023-47, Notice 2024-30, and Notice 2024-48.
Tax Credit Implications of the One Big Beautiful Bill Act | JD Supra
On May 22, the U.S. House of Representatives passed an amended version of H.R. 1—the One Big Beautiful Bill Act (the Bill) — by a vote of 215-214. The House-passed version of the bill, slated to be considered by the Senate this month, includes significant changes to the timing and availability of several clean energy tax credits, including the clean energy ITC (CEITC) and PTC (CEPTC), the clean hydrogen PTC, the advanced manufacturing credit, and the zero-emission nuclear PTC.
Treasury and IRS Issue Updated Domestic Content Guidance Under IRA and First Updated Elective Safe Harbor | JD Supra
On January 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-08 (Notice), which provides an updated safe harbor (First Updated Elective Safe Harbor) that modifies and otherwise clarifies the safe harbor (New Elective Safe Harbor) provided in Notice 2024-41 (which modified Notice 2023-38) that taxpayers may elect to use to calculate the domestic cost of Manufactured Products (defined below) and Manufactured Product Components (defined below)...
Treasury and IRS Issue Final Regulations on Clean Electricity Production and Investment Tax Credits | JD Supra
On January 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published final regulations providing further guidance on the clean electricity production credit under Section 45Y and the clean electricity investment credit under Section 48E. These final regulations follow the passage of the Inflation Reduction Act of 2022 (IRA) and the publication of proposed regulations under Sections 45Y and 48E.
IRS Issues Final Regulations on Clean Hydrogen Tax Credits | JD Supra
The IRS and the Treasury Department issued final regulations on January 3 (Final Regulations), providing guidance on the clean hydrogen production tax credit under Section 45V (Hydrogen PTC) and the investment tax credit under Section 48 (Hydrogen ITC).
IRS Issues Final Regulations on Section 45X Credits for Advanced Manufacturing Production Credit | JD Supra
November 1, 2024 Mitchell Emmert, Adam Kobos, Anne Loomis, Tsitsi Mangosho, McKenzie McAdams, Camille Mennen, Joel Post, Roger Reigner Jr. Troutman Pepper + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: On October 24, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the Advanced Manufacturing Production Credit (Section 45X Credit), pursuant to Section 45X...
IRS Issues Final Regulations on Prevailing Wages and Registered Apprenticeship Requirements | JD Supra
August 5, 2024 Mitchell Emmert, Adam Kobos, Anne Loomis, Tsitsi Mangosho, Camille Mennen, Roger Reigner Jr. Troutman Pepper + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: On June 18, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Regulations) on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing Wage Requirements) and (8)...
IRS Issues Final Regulations on Prevailing Wages and Registered Apprenticeship Requirements
On June 18, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Regulations) on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing Wage Requirements) and (8) (Apprenticeship Requirements) and substantially similar provisions in other sections of the Code (collectively, the PWA Requirements), which were added by the Inflation Reduction Act of 2022 (IRA).
'Energy Communities' Update May Clarify Tax Credit Eligibility
By Anne Loomis, Adam Kobos and Mitchell Emmert (June 17, 2024, 5:02 PM EDT) -- On June 7, the U.S. Department of the Treasury Department and the Internal Revenue Service issued Notice 2024-48, which includes lists of information that taxpayers may use to determine whether they meet certain requirements for energy communities under the statistical area category or the coal closure category.[1]... Law360 is on it, so you are, too.
Treasury and IRS Release Updated Guidance on Energy Communities
On June 7, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-48. This notice includes lists of information that taxpayers may use to determine whether they meet certain requirements for energy communities under the Statistical Area Category or the Coal Closure Category, each as described in Notice 2023-29. The IRS also updated the Frequently Asked Questions for Energy Communities (FAQs) on June 7.
Treasury and IRS Issue Additional Domestic Content Guidance Under IRA and New Elective Safe Harbor | JD Supra
On May 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-41, which modifies Notice 2023-38 (Prior Guidance) by expanding the list of Applicable Projects (defined below) to include hydropower and pumped hydropower storage facilities and provides a new safe harbor (New Elective Safe Harbor) that taxpayers may elect to use to calculate the domestic cost of Manufactured Products (defined below) and Manufactured Product Components (defined below)...
Treasury and IRS Issue Additional Domestic Content Guidance Under IRA and New Elective Safe Harbor
On May 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-41, which modifies Notice 2023-38 (Prior Guidance) by expanding the list of Applicable Projects (defined below) to include hydropower and pumped hydropower storage facilities and provides a new safe harbor (New Elective Safe Harbor) that taxpayers may elect to use to calculate the domestic cost of Manufactured Products (defined below) and Manufactured Product Components (defined below)...
IRS Issues Final Regulations on Tax Credit Transfers | JD Supra
Partnerships. Treasury and the IRS confirmed that, if a partnership has not elected direct pay for credits pursuant to Sections 45V, 45Q, or 45X, it may qualify as an eligible taxpayer for purposes of a tax credit transfer. However, the Preamble clarifies that Section 50(b)(3) and (4) may limit the ITCs determined with respect to any tax-exempt or government entity partner. Section 45Q Eligible Credit Property.
Energy Community Tax Credit Boost Will Benefit Wind Sector
ADVERTISEMENT Don't want ads? Subscribe or login now. By Thomas Phelan, Anne Loomis and Adam Kobos (April 15, 2024, 5:53 PM EDT) -- On March 22, the U.S. Department of the Treasury and the Internal Revenue Service issued Notice 2024-30, which modifies prior guidance on energy community enhancements.... A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.
Energy Community Tax Credit Boost Will Benefit Wind Sector
ADVERTISEMENT Don't want ads? Subscribe or login now. By Thomas Phelan, Anne Loomis and Adam Kobos (April 15, 2024, 5:53 PM EDT) -- On March 22, the U.S. Department of the Treasury and the Internal Revenue Service issued Notice 2024-30, which modifies prior guidance on energy community enhancements.... A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.
Treasury and IRS Release Further Guidance on Energy Community Enhancements Under IRA | JD Supra
On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore facilities are treated as "located in" an energy community, and (b) the requirements for a "Statistical Area Category" of the energy community safe harbor provided in Notice 2023-29, as previously modified by Notice 2023-45 and Notice 2023-47.
Treasury and IRS Release Further Guidance on Energy Community Enhancements Under IRA
On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore facilities are treated as “located in” an energy community, and (b) the requirements for a “Statistical Area Category” of the energy community safe harbor provided in Notice 2023-29, as previously modified by Notice 2023-45 and Notice 2023-47.
IRS Issues Proposed Regulations on Direct Pay | JD Supra
On June 14, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations and temporary regulations on direct pay of certain tax credits pursuant to Section 6417 of the Internal Revenue Code of 1986, as amended (Code), which was enacted by the Inflation Reduction Act.
IRS Issues Final Regulations on Direct Pay | JD Supra
On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the Internal Revenue Code of 1986, as amended (Code), which was enacted by the Inflation Reduction Act.
IRS Launches Pre-Filing Registration Portal | JD Supra
The IRS announced on December 22, 2023, that it has launched the pre-filing registration portal for direct payments under Section 6417 and tax credit transfers under Section 6418. The IRS has provided an overview of the registration process that includes a how-to video and a user guide.
IRS Launches Pre-Filing Registration Portal
The IRS announced on December 22, 2023, that it has launched the pre-filing registration portal for direct payments under Section 6417 and tax credit transfers under Section 6418. The IRS has provided an overview of the registration process that includes a how-to video and a user guide.
IRS Issues Proposed Regulations on Clean Hydrogen Tax Credits | JD Supra
The IRS and the Treasury Department issued proposed regulations on December 26, 2023 (Proposed Regulations), providing guidance on the clean hydrogen production tax credit under Section 45V (Hydrogen PTC) and the investment tax credit under Section 48 (Hydrogen ITC). The Proposed Regulations follow the passage of the Inflation Reduction Act of 2022 (IRA) and the publication of Notice 2022-58, 2022-47 I.R.B. 483, which requested comments on the Hydrogen PTC and Hydrogen ITC.
IRS Issues Proposed Guidance on Advanced Manufacturing Production Tax Credit Under IRA | JD Supra
[co-author: Kimmy Fishman] On December 14, the Department of the Treasury and the Internal Revenue Service (IRS), issued proposed regulations providing guidance on the Advanced Manufacturing Production Credit (Section 45X Credit), established by the Inflation Reduction Act of 2022 (IRA). The credit was established to incentivize production within the U.S. of eligible components related to the energy transition.
IRS Issues Proposed Guidance on Advanced Manufacturing Production Tax Credit Under IRA
On December 14, the Department of the Treasury and the Internal Revenue Service (IRS), issued proposed regulations providing guidance on the Advanced Manufacturing Production Credit (Section 45X Credit), established by the Inflation Reduction Act of 2022 (IRA). The credit was established to incentivize production within the U.S. of eligible components related to the energy transition.
Guidance Suggests U.S. Clean Vehicle Subsidies Require Disengagement From China Supply Chains | JD Supra
On December 1, the U.S. Department of Energy (DOE) released long-awaited proposed guidance defining "foreign entity of concern" (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Simultaneously, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued proposed guidance under Section 30D, the Clean Vehicle Tax Credit. The deadline for providing comments to DOE is January 3, 2024, and for providing comments to the IRS is January 18, 2024.
Guidance Suggests U.S. Clean Vehicle Subsidies Require Disengagement From China Supply Chains
On December 1, the U.S. Department of Energy (DOE) released long-awaited proposed guidance defining “foreign entity of concern” (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Simultaneously, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued proposed guidance under Section 30D, the Clean Vehicle Tax Credit. The deadline for providing comments to DOE is January 3, 2024, and for providing comments to the IRS is January 18, 2024.
IRS Issues Proposed Regulations on Energy Property and Rules Applicable to Energy Credit Under Section 48 | JD Supra
The IRS and the Treasury Department issued proposed regulations under Section 48 on November 22, 2023 (Proposed Regulations), providing further guidance in determining whether property is energy property and eligible for the Section 48 credit (ITC).
IRS Issues Proposed Regulations on Energy Property and Rules Applicable to Energy Credit Under Section 48
The IRS and the Treasury Department issued proposed regulations under Section 48 on November 22, 2023 (Proposed Regulations), providing further guidance in determining whether property is energy property and eligible for the Section 48 credit (ITC).
IRS Issues Proposed Regulations on Prevailing Wage and Apprenticeship Requirements under the IRA | JD Supra
The Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing Wage Requirements) and (8) (Apprenticeship Requirements) and substantially similar provisions in other sections of the Code (collectively, the PWA Requirements), which were added by the Inflation Reduction Act of 2022 (IRA).
IRS Issues Proposed Regulations on Prevailing Wage and Apprenticeship Requirements under the IRA
The Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing Wage Requirements) and (8) (Apprenticeship Requirements) and substantially similar provisions in other sections of the Code (collectively, the PWA Requirements), which were added by the Inflation Reduction Act of 2022 (IRA).
Court Issues Perplexing Decision in Alta Wind | JD Supra
On June 20, the U.S. Court of Federal Claims issued an opinion and order, denying plaintiffs' motion for summary judgment in Alta Wind I Owner-Lessor C, et al. v. U.S. (Nos. 13-402, 13-917, 13-935, 13-972, 14-47, 14-93, 14-174, 14-175, 17-997).
Court Issues Perplexing Decision in Alta Wind
On June 20, the U.S. Court of Federal Claims issued an opinion and order, denying plaintiffs’ motion for summary judgment in Alta Wind I Owner-Lessor C, et al. v. U.S. (Nos. 13-402, 13-917, 13-935, 13-972, 14-47, 14-93, 14-174, 14-175, 17-997).
Treasury and IRS Release Additional Guidance on Energy Community Enhancements Under IRA | JD Supra
On June 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-45 and Notice 2023-47. Notice 2023-45 clarifies requirements for a brownfield site energy community safe harbor provided in Notice 2023-29. Notice 2023-47 publishes lists of information that taxpayers may use to determine whether they meet certain requirements under the Statistical Area Category or the Coal Closure Category, each as described in Notice 2023-29.
IRS Issues Proposed Regulations on Tax Credit Transfers | JD Supra
June 20, 2023 Mitchell Emmert, Adam Kobos, Anne Loomis, Roger Reigner Jr. Troutman Pepper + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: On June 14, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations and temporary regulations on tax credit transfers pursuant to Section 6418 of the Internal Revenue Code of 1986, as amended (Code), which was enacted by the Inflation Reduction Act.
IRS Issues Proposed Regulations on Direct Pay
On June 14, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations and temporary regulations on direct pay of certain tax credits pursuant to Section 6417 of the Internal Revenue Code of 1986, as amended (Code), which was enacted by the Inflation Reduction Act.
Treasury and IRS Issue Domestic Content Guidance Under IRA | JD Supra
On May 12, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-38, which describes certain rules that Treasury and the IRS intend to include in forthcoming proposed regulations concerning domestic content.
Treasury and IRS Issue Domestic Content Guidance Under IRA
On May 12, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-38, which describes certain rules that Treasury and the IRS intend to include in forthcoming proposed regulations concerning domestic content.
Updated IRS Guidance on Critical Minerals and Battery Components Has Demonstrable, Ongoing Implications for Domestic and Foreign EV Manufacturing | JD Supra
[co-author: Alec Williams]* Introduction On March 31, the Internal Revenue Service (IRS) issued highly anticipated proposed regulations on electric vehicle (EV) tax credits. Driven by an ambitious climate agenda, the Biden administration has incentivized domestic manufacturing over the last three years through the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act of 2022 (IRA).
Updated IRS Guidance on Critical Minerals and Battery Components Has Demonstrable, Ongoing Implications for Domestic and Foreign EV Manufacturing
Introduction On March 31, the Internal Revenue Service (IRS) issued highly anticipated proposed regulations on electric vehicle (EV) tax credits. Driven by an ambitious climate agenda, the Biden administration has incentivized domestic manufacturing over the last three years through the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act of 2022 (IRA).
Treasury and IRS Release Guidance on Energy Community Enhancements under the Inflation Reduction Act | JD Supra
On April 4, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-29, which describes certain rules that Treasury and the IRS intend to include in forthcoming proposed regulations concerning energy communities.
Treasury and IRS Release Guidance on Energy Community Enhancements under the Inflation Reduction Act
On April 4, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-29, which describes certain rules that Treasury and the IRS intend to include in forthcoming proposed regulations concerning energy communities.
Keys to IRA Tax Breaks for US Green Energy, EV Production | JD Supra
Published inLaw360on November 16, 2022. © Copyright 2022, Portfolio Media, Inc., publisher of Law360. Reprinted here with permission. On Aug. 16, President Joe Biden signed the Inflation Reduction Act into law. The legislation includes landmark tax incentives for domestic energy production and manufacturing, with the goal of reducing carbon emissions in the U.S. by roughly 40% by 2030.
Treasury and IRS Release Guidance on Prevailing Wage, Apprenticeship, and Beginning of Construction Requirements Under the Inflation Reduction Act | JD Supra
[co-author: Brittany Johnson] Today, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published Notice 2022-61, providing guidance on the prevailing wage requirements under Section 45(b)(7)(A) and substantially similar provisions in other sections of the Internal Revenue Code (Code) (Prevailing Wage Requirements) and apprenticeship requirements under Section 45(b)(8) and substantially similar provisions in other sections of the Code (Apprenticeship Requirements), both...
New IRA Tax Incentives for US Manufacturing in Renewable Energy Sector | JD Supra
On August 16, President Biden signed the Inflation Reduction Act of 2022 (IRA) into law, which includes landmark tax incentives for domestic energy production and manufacturing with the goal of reducing carbon emissions in the United States by roughly 40% by 2030.
Inflation Reduction Act of 2022: Summary Chart | JD Supra
Please see Publication below for more information. Wind and Solar PTC and specified § 45 technologies - To embed, copy and paste the code into your website or blog: "My best business intelligence, in one easy email…" Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: By using the service, you signify your acceptance of
Inflation Reduction Act Brings Back Energy and Climate Provisions From Build Back Better Act
On July 27, Senator Manchin (D-WV) and Majority Leader Schumer (D-NY) reached an agreement to add the Inflation Reduction Act of 2022 (the Act) to the FY 2022 Budget Reconciliation Bill. The Act includes many climate and energy-related provisions from the Build Back Better Act (BBBA). The announcement of the Act came as a huge surprise, given Senator Manchin’s recent public statements that appeared to foreclose any climate and energy provisions in a successor to the BBBA.
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