A Rare Refund Opportunity: What the IEEPA Tariff Reversal Means for Energy, Manufacturing, and Infrastructure Clients

Overview There aren’t many situations where the government effectively says, “We’re giving the money back.” That’s what is now happening for certain importers. Following a recent Supreme Court decision, tariffs imposed under the International Emergency Economic Powers Act, or IEEPA, from 2025 through early 2026 have been struck down, and U.S. Customs and Border Protection … Read more

Provisions in the Section 48 and 48E Investment Tax Credits: Navigating Domestic Content Requirements for Elective Pay

Executive Summary The Inflation Reduction Act (IRA) of 2022 introduced transformative incentives for clean energy investments, including the Investment Tax Credit (ITC) under Sections 48 and 48E of the Internal Revenue Code. A key feature is the elective payment option, commonly known as “direct pay,” which allows certain entities—such as tax-exempt organizations, governments, and tribal … Read more

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