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On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).

Driven by the demand for AI-ready cloud infrastructure, the market cap for global data center construction, currently valued at more than $250 billion, is set to double in less than ten years, reaching half a trillion dollars by 2034.

On January 13, 2025, Texas Attorney General Ken Paxton (“Texas AG”) filed the first-ever enforcement action under the Texas Data Privacy and Security Act (“TDPSA”) against insurance company Allstate and its subsidiary, Arity (collectively, “Defendants”).

On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry.

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its Framework for Artificial Intelligence Diffusion, an Interim Final Rule revising the Export Administration Regulations (“EAR”) to expand controls on advanced computing integrated circuits, commonly called microchips (“ICs”) and impose new licensing requirements for artificial intelligence (“AI”) model weights (the “AI Diffusion Rule”).

As we previously discussed, on December 5, 2024, the Department of Justice (“DOJ”), representing the Department of the Treasury, submitted a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit, challenging a memorandum opinion and order issued by Judge Mazzant of the U.S. District Court for the Eastern District of Texas.

As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the Corporate Transparency Act (“CTA”), blocking implementation of the CTA in its entirety.

On December 4, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations [TD 10015] (the “Final Regulations”) for the energy credit available under section 48 (the “ITC”) of the Internal Revenue Code of 1986, as amended (the “Code”).

On September 18, 2024, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) (1) issued proposed regulations (the “Proposed Regulations”) providing guidance to taxpayers on the Alternative Fuel Vehicle Refueling Property Credit available under section 30C of the Internal Revenue Code of 1986, as amended (“30C Credit”) and (2) released Notice 2024-64 (the “Notice”)¹ to correct certain technical issues related to mapping tools used to identify eligible census tracts for the 30C Credit.²

On August 30, 2024, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) providing additional guidance to taxpayers on the “Low-Income Communities Bonus” (“LICB”) available under section 48E(h) of the Internal Revenue Code of 1986, as amended.

On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage and apprenticeship requirements (the “PWA Requirements”) impacting many of the clean energy tax credits introduced or expanded by the Inflation Reduction Act of 2022 (the “IRA”).

On May 29, 2024, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations (REG-119283-23) (the “proposed regulations”) regarding the clean electricity production tax credit and the clean electricity investment tax credit provided by the Inflation Reduction Act of 2022 (the “IRA”)¹ and available under new sections 45Y and 48E, respectively, of the Internal Revenue Code of 1986, as amended (the “Code”).