Tax

On March 5, 2024, the U.S. Department of the Treasury and the Internal Revenue Service released the following guidance with respect to the elective payment election under Section 6417:

• Final regulations under Section 6417, which modify and finalize proposed regulations released on June 21, 2023;
• Proposed regulations under Section 761, which would expand the election to be excluded from Subchapter K to apply to certain unincorporated organizations organized exclusively for electricity generation; and
• Notice 2024-27, which requests comments regarding whether, in certain circumstances, the Direct Payment Election should be available for energy transition tax credits that are purchased by the taxpayer pursuant to Section 6418.

Continue Reading.