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Aliza Cinamon

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Aliza R. Cinamon leads Proskauer’s Environmental Group. She advises both U.S. and international clients on a broad spectrum of environmental issues in connection with complex corporate, real estate, financing and bankruptcy transactions. Aliza provides clients with a deep array of capabilities, acting on matters that involve liability and risk allocation issues, remediation, brownfields, ESG, sustainability and climate change, public company disclosures, environmental insurance and technical expert management. Her practice also includes representing clients in superfund litigation matters, environmental compliance and permitting and federal and state environmental enforcement proceedings. She has worked on transactions involving both public and private companies covering a wide variety of industries including pharmaceuticals, chemical manufacturing, life sciences, telecommunications, real estate construction and development, sports and retail.

Aliza is also devoted to pro bono matters, including heading the Firm’s efforts on behalf of Holocaust victims eligible for reparations, obtaining disability benefits for veterans, identifying and assisting potential victims of trafficking, helping persecuted Iraqis seeking refuge in the U.S. and providing corporate counseling for a number of the Firm’s other pro bono clients. Before joining Proskauer, Aliza interned for the U.S. District Court, New York, Southern District with Judge Shira Scheindlin.

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I. Executive Summary

On February 15, 2024, the IRS and Treasury issued a supplemental notice to a prior notice from December 2022, to correct a petition requesting that the Superfund Chemical Tax apply to polyphenylene sulfide. While the supplemental notice is narrow in scope, the IRS and Treasury have requested…

After a more than 26 year hiatus, on July 1, 2022, the Superfund chemical excise tax (the “Superfund Chemical Tax”) will again become effective. This excise tax, reinstated by the passage of the Infrastructure Investment and Jobs Act,[1] is imposed on manufacturers, producers, and importers of certain chemicals and chemical substances. As discussed below, the re-establishment of this tax may have significant financial, administrative, and operational impacts; thus, it is crucial that businesses potentially subject to this tax understand its applicability, obligations, and exceptions, for tax year 2022 and beyond.

Even for those who have dealt with the first iteration of this tax, there are many material differences in the resurrected tax regime, including the applicable tax rates on chemicals and the threshold for determining which chemical substances are taxable.