JoonBeom Pae

2 months ago | mondaq.com | Michelle Jewett |Daniel Kiely |JoonBeom Pae |Warren Payne

On January 7, 2025, the US Department of the Treasury("Treasury") and the Internal Revenue Service("IRS") issued final regulations (the "FinalRegulations") relating to technology-neutral tax credits forclean energy projects under Sections 1 45Y and 48E that were enacted aspart of the Inflation Reduction Act of 2022.

Jan 14, 2025 | mondaq.com | Michelle Jewett |Daniel Kiely |Isaac Maron |JoonBeom Pae

On December 4, 2024, the US Treasury and IRS issued finalregulations (TD 10015) clarifying the definition of energy propertyand rules for the energy credit under Section 48 of the InternalRevenue Code. Key updates include modifications to the definitionof qualified biogas property, rules for energy storage technology,energy property aggregation rules, and the application ofprevailing wage and apprenticeship requirements.

Nov 11, 2024 | mondaq.com | Daniel Kiely |Michelle Jewett |Isaac Maron |JoonBeom Pae

On October 24, 2024, the US Department of Treasury ("Treasury") and the Internal Revenue Service ("IRS") released final regulations (the "Final Regulations")1 on the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (the "Code").2 Section 45X, which was enacted in 2022 as part of the Inflation Reduction Act (the "IRA"), provides a production tax credit for "eligible components" of clean energy property, which include solar- and wind-energy components,...

Aug 20, 2024 | mondaq.com | JoonBeom Pae

The question of whether a foreign person's income would be treated as income "effectively connected" with a trade or business in the United States ("ECI") often invites significant confusion and challenges. The concept of "U.S. trade or business" is inherently ambiguous and fact dependent, unless a taxpayer can rely on certain statutory safe harbors.

Dec 8, 2023 | mondaq.com | Mark Leeds |Steven Garden |Michelle Jewett |JoonBeom Pae

For years, the YA Global litigation has attracted the attention of many tax practitioners and private fund industry stakeholders.