Dickson C. Chin
New York
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Articles by Dickson C. Chin
Initial Guidance Issued On The OBBBA Material Assistance Restrictions For Energy Tax Credits
Jones Day are most popular: within Accounting and Audit topic(s) The U.S. Department of the Treasury and the Internal Revenue Service ("IRS") have issued initial interim guidance on the material assistance restrictions introduced by the foreign entity of concern ("FEOC") rules under the One Big Beautiful Bill Act of 2025 ("OBBBA").
Initial Guidance Issued on the OBBBA Material Assistance Restrictions for Energy Tax Credits | JD Supra
On February 12, 2026, the Treasury and the IRS issued Notice 2026-15 (the "Notice"), providing the first piece of guidance on the new FEOC material assistance restrictions. These restrictions disallow certain energy-related tax credits if a taxpayer receives "material assistance" from a Prohibited Foreign Entity ("PFE").
IOSCO Report Provides Guidance That Can Help Dealers Avoid Insider Trading Scrutiny
Jones Day are most popular: within Accounting and Audit topic(s) The Situation: Both the Financial Industry Regulatory Authority ("FINRA") and the National Futures Association ("NFA") have implemented rules prohibiting the practice of "frontrunning." Criminal prosecutors and financial regulators have brought enforcement actions against dealers who traded ahead of client orders on the theory that the trading constituted misappropriation of client secrets.
IOSCO Report Provides Guidance that Can Help Dealers Avoid Insider Trading Scrutiny | JD Supra
In Short The Situation: Both the Financial Industry Regulatory Authority ("FINRA") and the National Futures Association ("NFA") have implemented rules prohibiting the practice of "frontrunning." Criminal prosecutors and financial regulators have brought enforcement actions against dealers who traded ahead of client orders on the theory that the trading constituted misappropriation of client secrets.
Proposed Regulations Issued On The Section 45Z Clean Fuel Production Credit
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
FERC Issues Anticipated Order On Data Center Co-Location In PJM Region
Jones Day are most popular: within Strategy and Accounting and Audit topic(s) As power demand surges, on December 18, 2025, the Federal Energy Regulatory Commission ("FERC" or "Commission") announced a much-anticipated order laying the groundwork for new rules governing the co-location of large loads alongside electric generation in the Pennsylvania-New Jersey-Maryland ("PJM") region.
FERC Issues Anticipated Order on Data Center Co-Location in PJM Region | JD Supra
FERC defines "co-located load" as "end-use customer load that is physically connected to the facilities of an existing or planned [generator] on the [generator's] side of the Point of Interconnection." While the order applies to any co-location arrangement, as the Commission news release stated, its intent is to "facilitate service of AI-driven data centers and other large loads." The order finds PJM's existing rules unjust and unreasonable because they fail to provide clear guidelines for...
ISDA Publishes EU Guarantee Of Origin Annex
Jones Day are most popular: within Strategy and Accounting and Audit topic(s) In Short The Situation: Demand for standardized documentation to support trading in EU guarantees of origin has grown alongside the desire in the public and private sectors to reduce carbon emissions and transition to cleaner energy. The Development: The International Swaps and Derivatives Association ("ISDA") is launching and publishing the ISDA EU Guarantee of Origin Annex ("ISDA GO Annex").
ISDA Publishes EU Guarantee of Origin Annex | JD Supra
In Short The Situation: Demand for standardized documentation to support trading in EU guarantees of origin has grown alongside the desire in the public and private sectors to reduce carbon emissions and transition to cleaner energy. The Development: The International Swaps and Derivatives Association ("ISDA") is launching and publishing the ISDA EU Guarantee of Origin Annex ("ISDA GO Annex").
Germany To Expand Industrial Decarbonization Support: EUR 6 Billion Initiative Adds CCS
Jones Day are most popular: within Criminal Law topic(s) Germany has unveiled an EUR 6 billion funding initiative that expands climate protection contracts to include carbon capture and storage (CCS), adjusts renewable energy deployment, and introduces regulatory relief for energy-heavy industries, including in the fields of chemicals, pulp and paper, steel, cement and lime, as well as ceramics, glass, and gypsum.
Why Can't We Be Friends? The SEC And CFTC Vow More Cooperation
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
Why Can't We Be Friends? The SEC and CFTC Vow More Cooperation | JD Supra
On September 5, 2025, the Securities and Exchange Commission ("SEC") and the Commodity Futures Trading Commission ("CFTC") released a joint statement (the "Statement") outlining a renewed commitment to regulatory cooperation and harmonization, with a particular focus on fostering innovation in digital assets, crypto products, and emerging trading platforms.
CFTC Issues Advisory to Clarify FBOT Registration Framework for Non-U.S. Crypto Exchanges to Access U.S.-based Participants | JD Supra
The FBOT registration framework, which has been in place since the 1990s, allows non-U.S. exchanges legally organized and operating outside the United States to offer trading access to U.S.-based participants, provided they register as FBOTs with the CFTC. The advisoryreaffirms that the FBOT registration framework applies to all asset classes, including digital assets, and aims to facilitate lawful onshore trading activity under CFTC oversight.
CFTC Issues Advisory To Clarify FBOT Registration Framework For Non-U.S. Crypto Exchanges To Access U.S.-based Participants
To promote regulatory clarity, on August 28, 2025, the Commodity Futures Trading Commission ("CFTC")'s Division of Market Oversight issued an advisory to reaffirm its longstanding foreign board of trade ("FBOT") registration framework for non-U.S. exchanges, including non-U.S. crypto exchanges, that seek to offer trading access to U.S.-based participants.
New "Beginning Of Construction" Guidelines Issued For Wind And Solar Tax Credits
The Internal Revenue Service ("IRS") has issued Notice 2025-42 to implement the One Big Beautiful Bill Act ("OBBBA") mandate to phase out the clean electricity production tax credit (§ 45Y) and investment tax credit (§ 48E) for wind and solar projects. The notice tightens the "beginning of construction" rules for these projects. The Inflation Reduction Act of 2022 introduced technology-neutral production and investment energy tax credits under sections 45Y and 48E.
New "Beginning of Construction" Guidelines Issued for Wind and Solar Tax Credits | JD Supra
The Internal Revenue Service ("IRS") has issued Notice 2025-42 to implement the One Big Beautiful Bill Act ("OBBBA") mandate to phase out the clean electricity production tax credit (§ 45Y) and investment tax credit (§ 48E) for wind and solar projects. The notice tightens the "beginning of construction" rules for these projects. Background The Inflation Reduction Act of 2022 introduced technology-neutral production and investment energy tax credits under sections 45Y and 48E.
Carbon Capture Utilization And Storage In The United States
Presidential Support The current presidential administration has expressed its continued support for the expansion of carbon capture and sequestration policies through executive orders and declaring a national energy emergency.
Carbon Capture Utilization and Storage in the United States | JD Supra
August 11, 2025 Alem Cesko, Dickson Chin, Stefanie McArdle, Kit Rockhill, Jeffrey Schlegel, Brian Sedlak, Seth Stukalin Jones Day + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: Jones Day released a White Paper titled, “CCUS Regulation and Incentives in the Asia-Pacific Region: A Comparative Table for Strategic Decision-Making.” This White Paper is a continuation on that topic, covering carbon capture utilization and storage...
Carbon Capture Utilization and Storage in the United States
In July, Jones Day released a titled, "CCUS Regulation and Incentives in the Asia-Pacific Region: A Comparative Table for Strategic Decision-Making." This is a continuation on that topic, covering carbon capture utilization and storage ("CCUS") in the United States. Insights by Jones Day should not be construed as legal advice on any specific facts or circumstances.
White House Releases Plan To Build U.S. AI Infrastructure
In Short The Situation: On July 23, 2025, the White House released "America's AI Action Plan" (the "Plan"), a comprehensive federal strategy to secure U.S. global leadership in artificial intelligence ("AI"). The Plan is structured around three pillars: (i) accelerating AI innovation; (ii) building robust AI infrastructure; and (iii) leading in international AI diplomacy and security.
White House Releases Plan to Build U.S. AI Infrastructure | JD Supra
In Short The Situation: On July 23, 2025, the White House released "America's AI Action Plan" (the "Plan"), a comprehensive federal strategy to secure U.S. global leadership in artificial intelligence ("AI"). The Plan is structured around three pillars: (i) accelerating AI innovation; (ii) building robust AI infrastructure; and (iii) leading in international AI diplomacy and security.
One Big Beautiful Bill Act— Impact on Energy Tax Credits | JD Supra
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White House Releases Plan to Build U.S. AI Infrastructure
The Situation: On July 23, 2025, the White House released "America's AI Action Plan" (the "Plan"), a comprehensive federal strategy to secure U.S. global leadership in artificial intelligence ("AI"). The Plan is structured around three pillars: (i) accelerating AI innovation; (ii) building robust AI infrastructure; and (iii) leading in international AI diplomacy and security.
One Big Beautiful Bill Act-Impact on Energy Tax Credits
Find out more about Lexology or get in touch by visiting our About page. The One Big Beautiful Bill Act (the "OBBBA"), which was passed on July 4, 2025, included several changes to the energy tax credits introduced and expanded by the Inflation Reduction Act of 2022. The key changes to these credits are summarized in this .
The One Big Beautiful Bill Becomes Law: Impact On Clean Energy Tax Credits
After successfully passing both the House of Representatives and Senate, the One Big Beautiful Bill Act (the "OBBBA") was signed into law by President Trump on July 4, 2025. The OBBBA includes numerous changes to the energy tax credits initially introduced and expanded under the Inflation Reduction Act of 2022 (the "IRA").
The One Big Beautiful Bill Becomes Law: Impact on Clean Energy Tax Credits | JD Supra
After successfully passing both the House of Representatives and Senate, the One Big Beautiful Bill Act (the "OBBBA") was signed into law by President Trump on July 4, 2025. The OBBBA includes numerous changes to the energy tax credits initially introduced and expanded under the Inflation Reduction Act of 2022 (the "IRA").
One Big Beautiful Bill Act-Impact On Energy Tax Credits
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
The One, Big, Beautiful Bill: Impact On Clean Energy Tax Credits
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
The One, Big, Beautiful Bill: Impact on Clean Energy Tax Credits | JD Supra
The Inflation Reduction Act of 2022 (the "IRA") sought to encourage investment in clean energy by introducing new, and expanding existing, energy tax credits. It also sought to encourage financing of clean energy projects by creating a market for taxpayers to buy and sell certain credits for cash. On May 12, the House Ways and Means Committee released a copy of "The One, Big, Beautiful Bill" (the "Bill").
Wallem brings project cargoes and carriers together
In the highly competitive breakbulk cargo sector, Wallem Ship Agency continues to benefit from its ability to serve clients with specific needs and niche market requirements. With a focus Southeast Asia, the ship management group is quietly optimistic, writes Dickson Chin, managing director at Wallem Ship Agency.
Draft Guidance On The Section 45Z Clean Fuel Production Credit
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
Draft Guidance on the Section 45Z Clean Fuel Production Credit | JD Supra
Beginning January 1, 2025, taxpayers may claim a credit for producing transportation fuels such as ethanol, biodiesel, and renewable natural gas and selling them to unrelated buyers. The credit amount depends on the fuel's lifecycle greenhouse gas emissions rate: A net-zero emissions fuel can generate a $1.00-per-gallon credit ($1.75 for sustainable aviation fuel), with decreasing amounts as emissions rise.
Final Clean Electricity Production And Investment Tax Credit Regulations Provide Taxpayers With Welcomed Guidance
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
Final Clean Electricity Production and Investment Tax Credit Regulations Provide Taxpayers With Welcomed Guidance | JD Supra
The Inflation Reduction Act of 2022 introduced the Section 45Y clean electricity production and Section 48E clean electricity investment tax credits. These credits are technology neutral and generally apply to any type of electricity generation that achieves zero greenhouse gas emissions.
Final Regulations Issued In Final Days Of Congress: Clean Hydrogen Production Tax Credit
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
Final Regulations Issued in Final Days of Congress: Clean Hydrogen Production Tax Credit | JD Supra
The Inflation Reduction Act of 2022 introduced the Section 45V clean hydrogen production tax credit to spur domestic hydrogen production. The hydrogen production credit covers qualified hydrogen produced using both electricity and methane. To qualify for the credit, the hydrogen production process must result in lifecycle greenhouse gas ("GHG") emissions of four kilograms or less of carbon dioxide equivalents per kilogram of hydrogen produced.
The CFTC Finalizes Guidance On Voluntary Carbon Credit Contracts For Derivatives Markets
The Commodity Futures Trading Commission (“CFTC” or “Commission”) has inserted itself in recent years into efforts to scale the cash market for “high integrity” voluntary carbon credits. On September 20, 2024, the Commission approved final guidance regarding designated contract markets (“DCMs”) listing for trading voluntary carbon credit (“VCCs”) derivative contracts.
The CFTC Finalizes Guidance on Voluntary Carbon Credit Contracts for Derivatives Markets | JD Supra
The Commodity Futures Trading Commission (“CFTC” or “Commission”) has inserted itself in recent years into efforts to scale the cash market for “high integrity” voluntary carbon credits. On September 20, 2024, the Commission approved final guidance regarding designated contract markets (“DCMs”) listing for trading voluntary carbon credit (“VCCs”) derivative contracts.
Energy Transition And Social Infrastructure
JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs.
California's Climate Disclosure Laws Move Forward After Governor Newsom's Proposal to Delay Implementation Fails | JD Supra
Under Senate Bill ("SB") 253, the California Air Resources Board ("CARB") is required to adopt implementing regulations on or before January 1, 2025, and companies must start reporting their Scopes 1 and 2 emissions beginning in 2026, and their Scope 3 emissions beginning in 2027. Under SB 261, companies are required to submit their required biannual climate-related financial risk report on or before January 1, 2026 (see our prior Commentary for more details).
Corporate/Commercial Law
The California legislature continues to press forward with the implementation of two of the state's sweeping climate disclosure laws after a proposal to delay the implementation dates by the governor failed to be considered by the legislature.
Proposed Treasury Regulations Provide Guidance On New Clean Electricity Production And Investment Tax Credits
The Inflation Reduction Act of 2022 introduced a clean electricity production tax credit (Section 45Y of the Internal Revenue Code) and a clean electricity investment tax credit (Section 48E of the Internal Revenue Code). These credits begin to replace the existing Section 45 production tax credit and Section 48 investment tax credit for projects placed in service after 2024.
Proposed Treasury Regulations Provide Guidance on New Clean Electricity Production and Investment Tax Credits | JD Supra
June 3, 2024 Dickson Chin, Amie Colwell Breslow, Sean Jackowitz, Paul Johnson III, Edward Kennedy, Kelly Rubin, Jeffrey Schlegel, Brian Sedlak, Charles Wehland Jones Day + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits.
Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules | JD Supra
The Inflation Reduction Act of 2022 allows certain taxpayers to claim a tax credit for purchases of qualifying new clean vehicles (up to $7,500 per vehicle) and previously owned clean vehicles (up to $4,000 per vehicle). Clean vehicles generally include electric vehicles, plug-in hybrid electric vehicles, and hydrogen fuel cell vehicles.
Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules
The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits. The Inflation Reduction Act of 2022 allows certain taxpayers to claim a tax credit for purchases of qualifying new clean vehicles (up to $7,500 per vehicle) and previously owned clean vehicles (up to $4,000 per vehicle).
Administration Finalizes Regulations On Clean Energy Tax Credit Transfers - Renewables - United States
The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits. The Inflation Reduction Act of 2022 allows taxpayers to sell most types of clean energy tax credits to unrelated parties for cash. Clean energy developers and tax credit investors have begun to welcome tax credit sales as an alternative to complex tax equity structures.
Administration Finalizes Regulations on Clean Energy Tax Credit Transfers | JD Supra
The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits. The Inflation Reduction Act of 2022 allows taxpayers to sell most types of clean energy tax credits to unrelated parties for cash. Clean energy developers and tax credit investors have begun to welcome tax credit sales as an alternative to complex tax equity structures.
Administration Finalizes Regulations on Clean Energy Tax Credit Transfers
The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits. The Inflation Reduction Act of 2022 allows taxpayers to sell most types of clean energy tax credits to unrelated parties for cash. Clean energy developers and tax credit investors have begun to welcome tax credit sales as an alternative to complex tax equity structures.
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