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Treasury Releases New Beginning of Construction Guidance for Wind and Solar

Treasury and the IRS today released guidance, Notice 2025-42 (the “Notice”), regarding what constitutes beginning of construction for solar and wind energy projects with respect to the production tax credit under Section 45Y...more

ITC and PTC Changes Under the Big Beautiful Bill Act

President Trump last week signed into law the One Big Beautiful Bill Act (the “Act”). The Act made a number of changes to the clean electricity production credit under Section 45Y of the Internal Revenue Code (the “PTC”), the...more

Executive Order on PTC and ITC Beginning of Construction

President Trump yesterday issued an executive order, “Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources” (the “Executive Order”), which could have a major impact on wind and solar energy...more

U.S. Senate Proposes Changes to ITC and PTC

The United States Senate Committee on Finance this afternoon released draft text of its version of the “One Big Beautiful Bill,” which is available here. Although we are continuing to review the draft legislation, at a high...more

Key Provisions of the One Big Beautiful Bill (H.R.1) Related to Foreign Ownership and Foreign Supply (FEOC)

Applicable Limitations on Tax Credits under Sections 48E, 45Y, and 45X: The below summary describes provisions in the One Big Beautiful Bill that were passed by the House and are currently under consideration in the...more

High-Level Overview of certain Provisions Impacting Renewable Energy Incentives in “The One, Big, Beautiful Bill” Draft...

May 12th, the House Ways and Means Committee released a package of tax provisions (the “Bill”) that includes claw backs of certain provisions of the Inflation Reduction Act. Note that this Bill is a draft only, has not been...more

Final Regulations for New Clean Energy Production and Investment Tax Credits

Share on Twitter Print Share by Email Share Back to top Last week, the Internal Revenue Service (“IRS”) and Department of the Treasury issued the highly anticipated final regulations for the Clean Electricity Production Tax...more

IRS Releases Final Regulations for Section 45X Advanced Manufacturing Credit

The Internal Revenue Service (“IRS”) and Department of the Treasury last week released final regulations (the “Final Regulations”) relating to the advanced manufacturing production tax credit under Section 45X (“45X Credits”)...more

IRS Releases Final Tax Credit Sale Regulations

Late last week, the Internal Revenue Service (“IRS”) and Department of the Treasury released final regulations relating to transfers of certain tax credits pursuant to Section 6418 of the Code (the “Code” and, such rules, the...more

IRS Releases Final Direct Pay Regulations

The Internal Revenue Service (“IRS”) and Department of the Treasury earlier this week released final regulations relating to direct cash payments for certain tax credits pursuant to Section 6417 of the Internal Revenue Code...more

IRS Releases Proposed Regulations for Section 45X Advanced Manufacturing Credit

Earlier this month, the Internal Revenue Service (“IRS”) and Department of the Treasury released proposed regulations (the “Proposed Regulations”) relating to the advanced manufacturing tax credit under Section 45X of the...more

IRS Opens Tax Credit Transfer Portal

The Internal Revenue Service on Friday opened the registration portal for taxpayers selling eligible tax credits, including investment tax credits and production tax credits. The portal also permits tax-exempt and other...more

IRS Releases Proposed Tax Regulations for Clean Hydrogen

The Internal Revenue Service today released much anticipated proposed regulations with respect to the Section 45V tax credit for the production of clean hydrogen, which we expect will generate significant comments. The Foley...more

IRS Releases Guidance on Tax Credit Sales and Direct Cash Payments

The Internal Revenue Service (“IRS”) and Department of the Treasury earlier this week released extensive proposed regulations relating to direct cash payments for certain tax credits pursuant to Section 6417 of the Internal...more

IRA Tax Credits Benefit Energy and Manufacturing

The passage of the Inflation Reduction Act (IRA) in August of last year saw the introduction of a number of new and expanded tax credits aimed at boosting onshore American manufacturing. These incentives represent...more

New Rules for the EV Tax Credit under the Inflation Reduction Act

The Internal Revenue Service (IRS) recently released guidance regarding the changes to the Plug-In Electric Drive Vehicle Credit (EV Credit) under Section 30D of the Internal Revenue Code (Code), which was most recently...more

Prevailing Wage and Apprenticeship Guidance for ITC and PTC

On November 30, 2022, the Department of the Treasury and the Internal Revenue Service published Notice 2022-61 (the “Guidance”) describing how to satisfy certain prevailing wage and apprenticeship requirements (the “PWA...more

EV Charging Station Tax Credits are Back: Inflation Reduction Act Extension of the Section 30C Tax Credit

After expiring at the end of 2021, the Internal Revenue Code Section 30C tax credit for electric vehicle charging stations is back. Technically referred to as the “Alternative Fuel Vehicle Refueling Property Credit,” the...more

The Inflation Reduction Act: Key Provisions Regarding the ITC and PTC

On August 12, 2022, the House of Representatives passed the Inflation Reduction Act of 2022 (the “Act”), which the Senate passed on August 7, 2022.  President Biden has indicated that he will sign the Act into law....more

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