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Tax Bill Enacted on July 4, 2025 Contains Scaled-back Renewable Energy Provisions

On July 4, 2025, President Donald Trump signed the One Big, Beautiful Bill Act into law, which scales back renewable energy tax provisions. The final bill did, however, contain more favorable renewable energy tax provisions...more

Senate and House Pass BBB With Favorable Renewable Energy Credit Provisions, Bill Awaits Trump’s Signature

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

Senate Version of BBB Would Extend Runway for Renewable Energy Tax Credits, Preserve Transferability

On June 16, 2025, the Senate Finance Committee released the text of its version of the “One Big, Beautiful Bill Act,” which would phase out the investment tax credit (ITC) under Section 48E and production tax credit (PTC)...more

Amended House Bill Would Eliminate ITC and PTC for New Renewable Projects

On May 22, 2025, the House passed an amended version of the “One, Big, Beautiful Bill,” which would make the investment tax credit (ITC) under Section 48E and production tax credit (PTC) under Section 45Y unavailable for...more

Tax Bill Proposes Phasedowns in ITC and PTC, Limits on Transferability

On May 12, 2025, the House Ways and Means Committee released a draft of the Republican-sponsored 2025 tax bill, which addresses a number of renewable and clean energy tax credit matters previously extended in the Inflation...more

IRS Issues New Safe Harbor for 10% Domestic Content Bonus

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

IRS Issues Guidance for Direct Payments of Energy Tax Credits

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

IRS Issues Guidance Transferability Energy Tax Credits

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

Domestic Content 10% Bonus Guidance Released (IRS Notice 2023-38)

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

IRS Issues Guidance for Energy Community Bonus Tax Credits – Notice 2023-29

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

Energy Credits — Treasury, IRS Promise Direct Pay and Transferability Registry and Guidance

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

Inflation Reduction Act Extends and Modifies Tax Credits for Solar Projects

On Aug. 16, 2022, President Joe Biden signed into law the Inflation Reduction Act of 2022 (IRA), which includes new and revised tax incentives for clean energy projects. This alert provides a summary of the IRA impact on...more

IRS Issues Prevailing Wage and Apprenticeship Guidance — Starts 60-Day Clock

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

Inflation Reduction Act Extends and Modifies Tax Credits for Wind Projects

On Aug. 16, 2022, President Biden signed into law the Inflation Reduction Act of 2022 (IRA), which includes new and revised tax incentives for clean energy projects. The IRA extends and significantly modifies the federal tax...more

U.S. Senate Introduces the Inflation Reduction Act

On July 27, 2022, U.S. Senate Majority Leader Chuck Schumer (D-N.Y.) and Sen. Joe Manchin (D-W.V.) introduced the Inflation Reduction Act of 2022, which proposes new and revised tax incentives for clean energy. The bill...more

IRS Further Extends Continuity Safe Harbor for 2016 and Later Renewable Energy Projects

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

U.S. Senate Introduces the Clean Energy for America Act

On April 21, 2021, U.S. Senate Finance Committee Chairman Ron Wyden (D-Ore.) and 24 Democratic senators introduced the Clean Energy for America Act, which proposes to consolidate the current energy tax incentives available...more

Continuity Safe Harbor Extended for Offshore Wind, Renewable Energy Projects on Federal Land

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

Wind PTC and Solar ITC Gain COVID-19 Construction Relief From IRS

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

2019 Tax Credit Inflation Adjustment Factor: 2.5 Cents per kWh for Wind Facilities

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

IRS Provides Solar ITC Guidance on the Begin-Construction Requirement

On June 22, the IRS issued Notice 2018-59, providing guidance to determine when construction has begun on energy facilities, for purposes of the Section 48 investment tax credit. The long-awaited guidance follows changes...more

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