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New Final Tax Credit Transferability Regulations Issued; Changes Minimal

On April 25, 2024, the IRS and US Treasury Department issued the final regulations under Section 6418 of the Code, the provision that allows sales of certain tax credits, including credits for renewable energy production and...more

Fund Formation and Credit Transfers: Monetizing Tax Credits Using Partnerships

Section 6418 of the Internal Revenue Code (as added by the Inflation Reduction Act of 2022) allows an eligible taxpayer that qualifies for certain clean energy tax credits, including investment tax credits and production tax...more

Top 10 Things to Know: Proposed Regs for Renewable Energy Direct Pay & Direct Transfer

On Wednesday, June 14, 2023, the Internal Revenue Service (IRS) and U.S. Department of Treasury (Treasury) issued proposed Treasury Regulations on the elective payment of certain tax credits (also known as direct pay) under...more

Carbon Capture Tax Credit Ruling Issued

On July 1, 2021, the IRS issued Revenue Ruling 2021-13, allowing taxpayers that claim the carbon capture tax credit under Section 45Q to own part (but not all) of the carbon capture equipment. This important ruling clears the...more

Will Congress Recast the Economics of Renewable Energy Project Development and Investment?

As the 117th Congress works to enact legislation implementing President Biden’s “Build Back Better Recovery Plan,” extending and expanding current renewable energy tax incentives will be an integral part of the discussion....more

Congress Passes Energy Tax Credit Extenders

On December 21, 2020, Congress passed a series of energy tax credit extenders and additions as part of the omnibus spending and coronavirus relief bill. The bill has not yet been signed by President Trump....more

IRS Publishes Guidance on the Carbon Capture Tax Credit

On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more

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