Insights

Washington, D.C. – January 2, 2015: Crowell & Moring LLP is pleased to announce that it has elected six attorneys to the firm's partnership effective January 1, 2015. The firm has also promoted eight associates to the position of counsel. The new partners and counsel have been promoted from within the ranks of the firm's Washington, D.C., Brussels, New York, Orange County, and San Francisco offices.

Washington, D.C. – January 17, 2013: Crowell & Moring LLP is pleased to announce it has elected seven attorneys to the firm's partnership effective January 1, 2013. The firm has also promoted three attorneys to the position of senior counsel, and nine associates to the position of counsel. The new partners, senior counsel, and counsel have been promoted from within the ranks of the firm's Washington, D.C., San Francisco, Brussels, and London offices.

On March 23rd, the Treasury Department and the IRS published a notice of proposed rulemaking for the Section 48D Advanced Manufacturing Investment Credit (“Section 48D credit”) established by the CHIPS Act of 2022. Over the last few years, the market for semiconductors has been volatile, causing supply chain shortages. The Section 48D credit aims to incentivize investments in facilities that manufacture semiconductors or semiconductor manufacturing equipment in the United States, with the goal of creating American jobs and strengthening the U.S. economy and national security.

On December 29, 2022, the IRS released new guidance on whether vehicles qualify for tax credits under the clean vehicle provisions of the Inflation Reduction Act (the “IRA”). At the same time, Treasury released a much-anticipated White Paper describing the Administration’s planned approach to assessing whether vehicles meet the critical mineral content and battery processing requirements of the IRA.

Two Tax Court cases released last week highlight the importance—and the difficulty—of determining where a traveling worker "lives" for tax purposes. The concept of "tax home" has long been a source of confusion and uncertainty for employees that travel frequently or for extended periods. Such an employee may not have a tax home in the same location as his personal home, and in fact may not have a tax home at all.

All multinational enterprises are engaged in cross-border transfer pricing, even if they do not have an explicit policy. Moreover, the tax reporting around transfer pricing can present a substantial risk, even where the company is not taking advantage of low tax jurisdictions. This webcast will provide an introduction to the tax risks associated with company transfer pricing policies and the tools available to mitigate those risks.

Please join us on Wednesday, January 11, 2023 for a complimentary one-hour webinar addressing several of the most important requirements for earning enhanced tax credits under the IRA.