On July 3, 2025, after a tumultuous week, the Senate and House passed a version of the One Big, Beautiful Bill Act that contains the most favorable renewable energy credit provisions in any iteration of the bill....more
On May 17, 2024, the IRS released Notice 2024-41, which provides new safe harbors for determining certain energy projects’ qualification for the 10% domestic content bonus under the production tax credit (PTC) and investment...more
On Nov. 17, 2023, the IRS and Treasury Department released a series of proposed regulations for the Section 48 investment tax credit (ITC) that the energy market has anticipated for nearly a decade. These proposed rules...more
The Internal Revenue Service announced on Sept. 14, 2023, an immediate moratorium on the processing of Employee Retention Credit (ERC) claims that is anticipated to last at least through the end of the year....more
On Aug. 29, 2023, the U.S. Department of the Treasury and the IRS released comprehensive proposed regulations adding clarity to the prevailing wage and apprenticeship (PWA) prerequisites associated with eligibility for...more
The Inflation Reduction Act of 2022 created new opportunities both in renewed and brand-new energy tax credits. It also offered new methods through which these credits can be claimed, as a Section 6417 direct payment to...more
The Inflation Reduction Act of 2022 created new opportunities both in renewed and brand-new energy tax credits. It also offered new methods through which these credits can be claimed, as a Section 6417 direct payment to...more
The Inflation Reduction Act of 2022 (IRA) extended and modified a federal investment tax credit for advanced energy manufacturing projects under Section 48C of the Code. Section 48C provides incentives for clean energy...more
The Inflation Reduction Act of 2022 (IRA) created a 10% tax credit adder to encourage the use of “domestic content” in renewable projects that qualify for the production tax credit (PTC) and investment tax credit (ITC)....more
The Inflation Reduction Act of 2022 (IRA) created several new tax incentives to encourage the development of clean energy projects that would benefit specific communities. Among these incentives, Congress included a tax...more
Direct pay and transferability for energy tax credits have been available since Jan. 1, 2023, but credit transactions using these provisions have been slow to materialize due to lack of Treasury or IRS guidance. On March 22,...more
The Inflation Reduction Act of 2022 (IRA) created several new tax incentives to encourage developing clean energy projects that would benefit underserved communities and individuals. Among these incentives, Congress included...more
The Inflation Reduction Act of 2022 (IRA) created many new and revised tax incentives to develop clean energy projects. Among many of these incentives, Congress included a requirement that taxpayers meet prevailing wage and...more
On June 29, 2021, the IRS issued Notice 2021-41, providing taxpayers additional relief for purposes of satisfying the beginning-of-construction requirement for qualifying production tax credit (PTC) and investment tax credit...more
The U.S. Department of the Treasury and IRS recently issued final regulations regarding carbon capture tax credits under section 45Q of the Internal Revenue Code, which amend and clarify the proposed regulations issued last...more
The IRS recently issued Notice 2021-05, which extends the continuity safe harbor to 10 years for offshore wind projects and renewable energy projects constructed on federal land. Under prior IRS guidance, most renewable...more
On May 28, 2020, the IRS issued proposed regulations regarding carbon capture tax credits under Section 45Q of the Internal Revenue Code. The proposed regulations provide rules on secure geological storage, credit recapture,...more
On May 27, 2020, the Internal Revenue Service issued Notice 2020-41, providing taxpayers with relief for purposes of satisfying the beginning-of-construction requirement for qualifying production tax credit (PTC) and...more
On Feb. 20, 2020, the IRS issued Notice 2020-12 and Revenue Procedure 2020-12 regarding carbon capture tax credits (IRC Section 45Q). Notice 2020-12 (the begin construction notice) provides guidance to determine when...more
2/25/2020
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The U.S. Treasury Department and the Internal Revenue Service (IRS) recently issued proposed regulations providing guidance to taxpayers on the tax consequences of modifying financial instruments and contracts in advance of...more
The Internal Revenue Service recently published its annual notice providing the inflation adjustment factors and reference prices used in determining the amount of production tax credits (PTCs) for renewable energy and...more
Earlier this month, the Internal Revenue Service issued Notice 2019-43, which modifies guidance provided in prior Notices 2013-29, 2013-60, 2014-46, 2015-25, 2016-31, 2017-04 and 2018-59 to provide that the continuity safe...more
In February 2018, the tax credit for carbon capture and sequestration under Section 45Q of the Internal Revenue Code (the carbon sequestration credit) received a significant boost from Congress in the Bipartisan Budget Act of...more
On Dec. 13, 2018, the Internal Revenue Service and Department of Treasury issued proposed regulations addressing the base erosion and anti-abuse tax (BEAT). In general, the regulations provide guidance for identifying an...more
On Oct. 19, the IRS and Treasury Department issued proposed regulations and a Revenue Ruling as the first part of its long-anticipated guidance package regarding the Opportunity Zone program. Enacted at the end of last year...more