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IRS and Treasury Tighten Beginning-of-Construction Rules for Wind and Solar

On Aug. 15, the U.S. Treasury Department and the Internal Revenue Service (IRS) released IRS Notice 2025-42, narrowing the rules for what qualifies as “beginning of construction” (BOC) under the One Big Beautiful Bill Act...more

‘One Big Beautiful Bill Act’ Signed Into Law and Executive Order With Major Impacts on Clean Energy Tax Credits

On July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA), a budget reconciliation package that significantly modifies the clean energy tax credit framework established by the Inflation...more

House Bill Accelerates Phaseout of Clean Energy Tax Credits and Restricts Leasing and Transferability

On May 22, 2025, the U.S. House of Representatives passed House Bill 1, officially titled the “One Big Beautiful Bill Act” (OBBBA). This budget reconciliation bill includes significant energy-related provisions that would...more

New Executive Actions Potentially Impact Renewable Energy Projects

Among the wave of executive actions issued upon President Trump taking office again, some executive orders and memorandums may affect portions of the burgeoning renewable energy sector. The renewable energy sector has been...more

IRS and Treasury Release Final Rules for Technology-Neutral Clean Electricity Credits Under Sections 45Y and 48E

The Inflation Reduction Act of 2022 introduced the Code Section 45Y production tax credit (CEPTC) for facilities that generate clean electricity with zero greenhouse gas (GHG) emissions and the Code Section 48E investment tax...more

Treasury and IRS Finalize Clean Hydrogen Production Credit Regulations

The Inflation Reduction Act of 2022 added the Section 45V production tax credit for the production of clean hydrogen (Section 45V) to the Internal Revenue Code of 1986, as amended. Section 45V provides a credit against...more

Treasury and IRS Release Final Regulations on Section 45X Advanced Manufacturing Production Credit

The Inflation Reduction Act of 2022 added the Section 45X Advanced Manufacturing Production Credit (Section 45X) to the Internal Revenue Code of 1986, as amended. Section 45X provides a credit against federal income tax for...more

Treasury and IRS Provide Guidance on Energy Tax Credit Direct Payment Elections

The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more

Treasury and IRS Issue Long-Awaited Guidance on Energy Tax Credit Transfers

The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code of 1986, as amended (the “Code”), which allows taxpayers to elect to transfer all or any portion of certain energy tax credits to an...more

IRS Issues Initial Guidance on Domestic Content Bonus Credit for Energy Projects

The Inflation Reduction Act of 2022 (the “IRA”) added and modified certain renewable energy tax credit provisions of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). The IRA additions included a new domestic...more

IRS Issues Guidance on Low-Income Community Bonus Credit

The Inflation Reduction Act of 2022 (the “IRA”) added and modified certain renewable energy tax credit provisions of the U.S. Internal Revenue Code of 1986, as amended (the “Code”), including the provisions applicable to the...more

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