Wind and solar projects placed in service after 2027 would not be eligible for the clean electricity production or investment credit unless construction starts within one year of the date of enactment of the legislation....more
Wind and solar projects placed in service after 2027 would not be eligible for the clean electricity production or investment credit, and a new excise tax of up to 50% for wind and 30% for solar would be imposed on wind and...more
Proposed legislation would increase the Advanced Manufacturing Investment Tax Credit from 25% to 30% for projects started by the end of 2026. Substantial differences between House and Senate versions of the tax package will...more
Most tax credits would be subject to early termination dates and phase-outs. The House bill would end the ability to sell tax credits for cash, but the Senate Finance Committee proposal would restore transferability. New...more
On January 10, 2025, the Internal Revenue Service (IRS) issued Notice 2025-10 and Notice 2025-11. Notice 2025-10 summarizes proposed regulations (Proposed Regulations) that Treasury and the IRS plan to issue with respect to...more
On January 7, 2025, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations [TD 10024] (Final Regulations) providing guidance on the Clean Electricity Production Tax Credit...more
The final regulations retain the general framework of the proposed regulations, with some important modifications based upon comments from industry members.
The acquisition and retirement of energy attribute certificates...more
1/9/2025
/ Carbon Capture and Sequestration ,
Clean Energy ,
Department of Energy (DOE) ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
IRS ,
Methane ,
Natural Gas ,
Nuclear Power ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
The Final Regulations provide relief with respect to “impracticable-to-trace” battery materials.
The new guidance provides additional detail for the transition rule applicable to qualified manufacturers, including as...more
The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications.
The registration portal for transferring tax credits is open, and no significant changes have...more
5/6/2024
/ Clean Fuels Program (CFP) ,
Final Rules ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Passive Activity ,
Registration Requirement ,
Regulatory Standards ,
Renewable Energy Incentives ,
S-Corporation ,
Tax Credits ,
Tax Returns ,
U.S. Treasury
The application cycle for Treasury to award this round of credits will soon open, providing applicants an opportunity to receive significant funding for clean energy, industrial decarbonization and critical materials...more
5/6/2024
/ Clean Energy ,
Department of Energy (DOE) ,
Energy Sector ,
Greenhouse Gas Emissions ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Nuclear Power ,
Solar Energy ,
Tax Credits ,
U.S. Treasury ,
Wind Power
Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more
3/19/2024
/ Business Entities ,
Comment Period ,
Internal Revenue Code (IRC) ,
IRS ,
Joint Ownership ,
Partnerships ,
Proposed Regulation ,
Regulatory Agenda ,
Tax Credits ,
Tax Reform ,
Taxation ,
U.S. Treasury
The proposed regulations go beyond the use of the GREET model by requiring the use of “energy attribute certificates” (EACs) to prove eligibility for the credit under section 45V of the Internal Revenue Code (IRC). The use of...more
1/2/2024
/ Clean Energy ,
Department of Energy (DOE) ,
Energy Tax Incentives ,
European Commission ,
Greenhouse Gas Emissions ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury ,
Zero Emission Credits
The proposed regulations add new definitions to clarify what is required under foreign entity of concern (FEOC) compliance.
The Revenue Procedure provides guidance to qualified manufacturers on reporting and other...more
Under the IRA, select renewable energy credits are transferrable, including to individuals and pass-through entities.
The transferees of these credits are subject to the passive activity rules of Section 469 of the...more