Name
Tax Credits: Transferability and Direct Pay under the Inflation Reduction Act
Date & Time
Wednesday, January 10, 2024, 10:30 AM - 11:45 AM
Speakers
John Eliason, Partner, Orrick, Herrington & Sutcliffe, LLP
Shariff Barakat, Partner, Akin Gump Strauss Hauer & Feld LLP
Patrick Browne Jr., Adjunct Professor of Law, The Georgetown University Law Center, Marsh USA LLC
Sarah Haradon, Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury
Amber MacKenzie, Attorney Advisor, US Department of Treasury
Kelly Rubin, Partner, Jones Day
Jeremy Milton, Attorney, Branch 1, Office of the Associate Chief Counsel (Passthroughs and Special Industries), Internal Revenue Service
Shariff Barakat, Partner, Akin Gump Strauss Hauer & Feld LLP
Patrick Browne Jr., Adjunct Professor of Law, The Georgetown University Law Center, Marsh USA LLC
Sarah Haradon, Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury
Amber MacKenzie, Attorney Advisor, US Department of Treasury
Kelly Rubin, Partner, Jones Day
Jeremy Milton, Attorney, Branch 1, Office of the Associate Chief Counsel (Passthroughs and Special Industries), Internal Revenue Service
Description
Our panel entitled “Our Tax Credits: Transferability and Direct Pay under the IRA” will consider the new opportunities provided by the IRA to monetize federal tax credits through the use of “direct pay” and “transferability” provisions set forth in Sections 6417 and 6418 of the Code. We will be discussing the rules and getting the perspectives of both industry practitioners and Treasury and IRS representatives responsible for implementing the new legislation. Among other things, we will be discussing recently issued proposed Treasury Regulations and some of the complexities that taxpayers must overcome.