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Treasury Guidance Tightens "Beginning of Construction" Standards for Clean Energy Tax Credits, Eliminating 5% Safe Harbor for Wind...

On August 15, 2025, the Internal Revenue Service (IRS) issued Notice 2025-42, providing long-awaited guidance on the “beginning of construction” requirements for wind and solar facilities under Sections 45Y and 48E of the...more

OBBBA Extends, Modifies Opportunity Zone Program

One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

New Executive Order Targets Wind and Solar Tax Credits

On July 7, 2025, President Trump signed the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources.” The EO directs the Secretary of the Treasury to “strictly enforce” the...more

Senate Version of One Big Beautiful Bill Act Clarifies Foreign Entity Restrictions on Renewable Energy Tax Credits

The Senate Finance Committee recently released its own draft of the “One Big Beautiful Bill Act” (the Bill) previously passed by the House as H.R. 1. Both the House and Senate versions of the Bill impose restrictions on...more

IRS Releases Guidance on Domestic Content Bonus Credit Amounts

On May 12, 2023, in Notice 2023-38 (the “Notice”), the IRS published rules intended for inclusion in forthcoming regulations regarding domestic content bonus credit amounts. The Inflation Reduction Act of 2022 amended §§...more

Inflation Reduction Act to Greatly Increase IRS Funding

The Inflation Reduction Act of 2022 (IRA) includes increased Internal Revenue Service (IRS) funding in the amount of approximately $80 billion over ten years. According to a Congressional Research Service report, the law...more

Direct Pay Proposals in the Build Back Better Act and Observations from Industry Insiders

Under current law, there are significant tax benefits for renewable energy projects in the United States. These benefits include nonrefundable ITC and PTC tax credits and depreciation deductions. ...more

IRS Extends 2021 Tax Filing Deadline For Texas Taxpayers Impacted By Winter Storm

Following an announcement from the Internal Revenue Service (IRS) on February 22, 2021, Texas residents and business owners suffering from the February 2021 winter storm will now have until June 15, 2021, to file certain tax...more

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