On March 11, the Treasury Department and Internal Revenue Service (IRS) issued final regulations (Final Regulations) under Section 6417 of the Internal Revenue Code (Code), providing rules for the elective payment of applicable credits under Code Section 6417. Section 6417 of the Code allows certain applicable entities, including tax-exempt and government entities (Applicable Entities), to elect to receive direct payments from the IRS for these credits. 

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Photo of David Gillespie David Gillespie

David Gillespie is a transactional lawyer focusing on tax, energy transition and infrastructure. He regularly advises clients on energy-related tax credits under the Inflation Reduction Act from both project development and financing perspectives. His practice includes project development, tax-equity financings, cross-border and domestic…

David Gillespie is a transactional lawyer focusing on tax, energy transition and infrastructure. He regularly advises clients on energy-related tax credits under the Inflation Reduction Act from both project development and financing perspectives. His practice includes project development, tax-equity financings, cross-border and domestic mergers and acquisitions, leasing and other complex transactions, with a concentration in renewable energy. David’s experience includes advising developers, sponsors, major financial institutions, tax equity investors, energy and infrastructure funds, among others in a wide range of sectors, including solar, wind, battery storage, electric vehicles, carbon capture and sequestration, geothermal, nuclear, renewable natural gas, hydro, clean fuels, conventional power, transportation, social infrastructure, rail, aviation, and maritime.

David previously was a founder of an international advisory business for the structured financing of energy, transportation, and infrastructure assets.

Photo of Margaret J. Weil Margaret J. Weil

Margaret J. Weil focuses her practice on tax planning and advice for private equity transactions, mergers and acquisitions, financings, and other commercial transactions. She advises domestic and international corporations, partnerships, and high-net-worth individuals on a broad range of tax matters, including domestic and…

Margaret J. Weil focuses her practice on tax planning and advice for private equity transactions, mergers and acquisitions, financings, and other commercial transactions. She advises domestic and international corporations, partnerships, and high-net-worth individuals on a broad range of tax matters, including domestic and cross-border M&A, securities offerings, restructurings, tax compliance, and the federal, state, and international tax developments that affect their transactions and ongoing business operations.

Photo of Shivani Rumalla Shivani Rumalla

Shivani Rumalla focuses her practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. She regularly structures, drafts, and negotiates complex joint ventures throughout the United States and has experience advising clients on tax efficient structuring…

Shivani Rumalla focuses her practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. She regularly structures, drafts, and negotiates complex joint ventures throughout the United States and has experience advising clients on tax efficient structuring of real estate transactions, REIT formations, and corporate mergers and acquisitions. Shivani’s tax experience also includes advising a variety of businesses on the tax implications of inbound and outbound transactions, advising clients on the tax implications of a bankruptcy filing, and representing clients in federal tax controversy matters.