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From the Hill: October 10, 2023

New bills and proposals were introduced in Congress, including the Technologies for Energy Security Act, the MICROGRID Extension Act, and the Stop Tax Penalties on American Hostages Act.
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Lately on the Hill

Here’s a look at recent tax-related happenings on the Hill, which includes some newly introduced bills and IRS guidance related to certain triangular reorganizations.  


  • The IRS has published proposed regulations (REG-117614-14) that provide guidance on the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations.
  • The IRS has warned (IR-2023-185) taxpayers to be on alert for promotions regarding art donation deductions targeted at high-income filers and provided tips to help avoid these schemes.
  • The IRS has requested comments on Form 15254, “Request for Section 754 Revocation,” which is used by partnerships to request revocation of a Section 754 election in effect.

Related to the IRA & CHIPS Act

  • The IRS has released several pieces of guidance on the new clean vehicle credit and previously owned clean vehicle credit in IR-2023-186. The package includes: 
    • Proposed Regulations (REG-113064-23) for taxpayers who purchase qualifying new clean vehicles or qualifying previously owned clean vehicles and intend to transfer the credit amount to dealers that are eligible to receive advance payments of either credit. Under the proposed rules, consumers will be able to transfer the credit to an eligible dealer at the point of sale.
    • Revenue Procedure (Rev. Proc. 2023-33): This revenue procedure sets forth the procedures under Sections 30D(g) and 25E(f) of the Internal Revenue Code for the transfer of the clean vehicle credit or previously owned clean vehicle credit from the taxpayer who elects to transfer such credit to an eligible entity.
    • FAQ (FS-2023-22) revising and adding frequently asked questions on the credit. 
  • The IRS should improve and update computer programming relating to provisions under the Inflation Reduction Act to reduce taxpayer burdens, the Treasury Inspector General for Tax Administration said in a partially redacted report released October 5.

This newsletter features developing content that is subject to change at any time. It does not constitute legal or tax advice. Consult your professional advisors prior to acting on the information set forth herein.

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