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United States Senate Finance Committee Makes Changes to Clean Energy Provisions of the Proposed One Big Beautiful Bill

On June 16, 2025, the US Senate Committee on Finance released its legislative text (the “Senate Finance Committee version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently...more

House Reconciliation Bill Amends Clean Energy Provisions of the IRA

On May 22, 2025, the House of Representatives passed its reconciliation bill, H.R. 1, entitled “One Big Beautiful Bill Act” (the “legislation”), which significantly amends the clean energy provisions that were enacted as part...more

Treasury Issues Final Regulations on Technology Neutral Clean Energy Projects

On January 7, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) relating to technology-neutral tax credits for clean energy...more

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) to allow certain unincorporated organizations owned by specified “applicable...more

Treasury and IRS Issue Final Regulations on Section 45X

On October 24, 2024, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) on the Section 45X Advanced Manufacturing Production Credit of the...more

Outlook for Energy and Tax Policy in 2025

While we await the outcome of the upcoming US elections, stakeholders in the energy tax and policy space should recognize that, regardless of the outcome of the election, there will be plenty of activity in the energy sector...more

Final Regulations Issued on Prevailing Wage and Apprenticeship Requirements under the Inflation Reduction Act

On June 18, 2024, the US Internal Revenue Service (“IRS”) and Department of the Treasury (“Treasury”) issued final regulations (“Final Regulations”) establishing rules for taxpayers intending to satisfy the prevailing wage...more

IRS Releases 2022 Section 45 Production Tax Credit Amounts

On April 14, 2022, the US Internal Revenue Service (IRS) published a notice, which provides the inflation-adjustment factor and reference price for the calculation of renewable electricity production tax credits (PTCs) under...more

Solar and Wind Tax Credits Extended, Again

On Monday, December 21, 2020, the United States Congress passed a second large stimulus bill (the “Relief Bill”) aimed at curtailing the economic disruptions caused by COVID-19. ...more

Solar and Wind Tax Credits Extended, Again

On Monday, December 21, 2020, the United States Congress passed a second large stimulus bill (the “Relief Bill”) aimed at curtailing the economic disruptions caused by COVID-19. The Relief Bill, among other things, extends...more

IRS Provides Start-of-Construction Relief for Renewables in Light of COVID-19

On May 27, 2020, the US Internal Revenue Service (the “IRS”) released Notice 2020-41 (the “Notice”), updating the IRS guidance on the start-of-construction rules for the production tax credit (“PTC”) and energy investment tax...more

Final Regulations Published Addressing Income Inclusion Rules for Pass-Through Lease of ITC Property

On July 17, 2019, the US Internal Revenue Service (IRS) issued final regulations (T.D. 9872) providing guidance on the rules under Internal Revenue Code (IRC) section 50(d)(5) requiring an income inclusion by the lessee in...more

Maryland’s Energy Storage Tax Credit Turns Two

As previously discussed on this blog, Maryland, in 2017, become the first state in the county to offer an income tax credit for energy storage systems and, to our knowledge, as of 2019, it remains the only state to do so....more

Beginning of Construction Guidance for Solar and Other ITC Technologies

On June 22, 2018, the IRS released Notice 2018-59 (the “Guidance”). The Guidance provides rules to determine when construction begins with respect to investment tax credit (“ITC”) eligible property, such as solar projects. ...more

Residential Solar Storage is Eligible for Tax Credit, Subject to a 100% Cliff

In a recently released private letter ruling, the IRS confirmed that residential solar energy batteries are eligible for the tax credit under Section 25D of the Code (the “Residential Solar Credit”), subject to an important...more

Maryland Enacts First in the Nation Energy Storage Tax Credit

On May 4, 2017, Maryland became the first state in the country to offer a tax credit for energy storage systems with Governor Larry Hogan’s (R) signing of Senate Bill No. 758....more

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