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Clean Energy Energy Tax Incentives Internal Revenue Code (IRC)

Buchalter

Key Tax Changes in Public Law 119-21: What Individuals and Businesses Need to Know

Buchalter on

On July 4, 2025, the President signed into law Public Law 119-21 (the “Act”). For individuals, the Act makes the tax rate cuts of the 2017 Tax Cuts and Jobs Act (“2017 TCJA”) permanent, and modifies and introduces additional...more

Akin Gump Strauss Hauer & Feld LLP

Significant Cuts to IRA Clean Energy Tax Credits Included in Enacted Reconciliation Bill

President Trump signed the “One, Big, Beautiful Bill Act” (the “OBBB”) into law on July 4, 2025. Congress passed the legislation using the budget reconciliation process to avoid the 60-vote Senate filibuster. In addition to...more

Baker Botts L.L.P.

The "One Big Beautiful Bill Act" Substantially Alters Clean Energy Tax Landscape

Baker Botts L.L.P. on

On July 4, 2025, the legislation commonly known as the "One Big Beautiful Bill Act" (the “BBBA”) was enacted. The BBBA makes significant changes to the tax credits available under the Inflation Reduction Act of 2022 (the...more

Pierce Atwood LLP

Congress Phases Out Energy Tax Credits

Pierce Atwood LLP on

On July 3, 2025, Congress approved a version of the “One Big Beautiful Bill Act” (the Bill), which significantly impacts the energy tax credits enacted under the Inflation Reduction Act of 2022 (IRA). President Trump held a...more

Pillsbury Winthrop Shaw Pittman LLP

Congress Sends Big, Beautiful Bill for President’s Signature: Status of Clean Energy Tax Credits

Wind and solar projects placed in service after 2027 would not be eligible for the clean electricity production or investment credit unless construction starts within one year of the date of enactment of the legislation....more

Holland & Knight LLP

IRS Issues Updates for Energy Community Bonus Tax Credit

Holland & Knight LLP on

The IRS released additional guidance on June 23, 2025, in the form of Notice 2025-31 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...more

Hogan Lovells

Full U.S. House passes “One Big Beautiful Bill” – Impact on energy

Hogan Lovells on

On May 22, 2025 the House of Representatives, by a vote of 215-214 (no Democrats supporting), passed the One Big, Beautiful Bill Act (“OBBB”) which includes manager’s amendment changes from the version passed by the Ways and...more

Vinson & Elkins LLP

Treasury Releases Guidance and GREET Model for the Section 45Z Clean Fuel Production Credit

Vinson & Elkins LLP on

On January 10, 2025, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) continued their flurry of new guidance by releasing IRS Notice 2025-10 (the “Notice”) concerning the clean fuel...more

Bracewell LLP

Treasury Department and IRS Release Final Regulations for Section 45V Clean Hydrogen Production Tax Credit

Bracewell LLP on

On January 3, 2025, the Treasury Department and the Internal Revenue Service issued final regulations under Internal Revenue Code (Code) Section 45V (the Final Regulations) with respect to credits for the production of clean...more

Jones Day

Final Regulations Expand Access to "Direct Pay" Elections for Energy Credits

Jones Day on

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more

Cadwalader, Wickersham & Taft LLP

Charging Ahead or Stalling Out? Clean Energy Credits Await Key Guidance

The Inflation Reduction Act of 2022 (the “IRA”) allows firms to develop and sell clean energy tax credits. In our last update, available here, we discussed the release of the long-awaited guidance package on the new...more

Cadwalader, Wickersham & Taft LLP

Back in Session: Energy Tax Credits

The Inflation Reduction Act of 2022 (the “IRA”) allows firms to develop and sell clean energy tax credits.  In our last update, we discussed the uncertain future of energy tax credit sales as we head into the election....more

McNees Wallace & Nurick LLC

U.S. Treasury Proposes New Regulations on Eligibility Requirements for Clean Energy Tax Credits under the Inflation Reduction Act

The United States Department of the Treasury (Treasury) on June 3, 2024 published proposed regulations on Internal Revenue Code (IRC) Sections 45Y and 48E, which provide for clean energy production and investment tax credits...more

Mayer Brown

Final Regulations Issued on Direct-Pay Elections and Transfer of Tax Credits

Mayer Brown on

On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations under section 6418”) concerning the election to transfer...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations on Credit Transferability

On April 25, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) regarding the election to transfer energy tax credits under Section...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Propose Supplemental Notice Regarding Clean Hydrogen Production Tax Credit Regulations

On April 10, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of proposed rulemaking (the Supplemental Regulations) to supplement the Clean Hydrogen Production Tax...more

Cadwalader, Wickersham & Taft LLP

Green Means Go for Energy Tax Credit Sales

The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits.  Sales are officially underway....more

Partridge Snow & Hahn LLP

IRS Issues Much-Anticipated Regulations for Transferrable Clean Energy Tax Credits

The IRS recently issued proposed regulations describing rules for eligible taxpayers that may now elect to transfer certain clean energy credits to unrelated third parties under Section 6418 of the Internal Revenue Code (IRC)...more

Akin Gump Strauss Hauer & Feld LLP

Proposed Clean Hydrogen Guidance: Limitations on Credit Availability for Green Hydrogen Projects and Paths Forward

Guidance recently issued by the Department of the Treasury and the Internal Revenue Service (IRS) in proposed regulations (REG-117631-23) will (if held to be final) have a significant impact on green hydrogen projects in the...more

Bracewell LLP

Treasury and IRS Issue Proposed Regulations With Respect to Clean Hydrogen Credits Under Sections 45V and 48 of the Internal...

Bracewell LLP on

On December 22, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) released a notice of proposed rulemaking and notice of public hearing containing proposed regulations (Proposed Regulations) with...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Regulations on Section 45V Hydrogen Production Tax Credit

On December 22, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) regarding the Clean Hydrogen Production credit...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Proposed Regulations on the Clean Hydrogen Production Credit under Section 45V of the Internal...

The proposed regulations go beyond the use of the GREET model by requiring the use of “energy attribute certificates” (EACs) to prove eligibility for the credit under section 45V of the Internal Revenue Code (IRC). The use of...more

A&O Shearman

Treasury’s Proposed Regulations on Energy Property and the Energy Investment Tax Credit

A&O Shearman on

Among other things, the proposed regulations would: Below is a more detailed summary of the key provisions in the proposed regulations as well as our initial observations. The IRS will collect comments until January 22, 2024,...more

Cadwalader, Wickersham & Taft LLP

Treasury Gearing Up for Energy Tax Credit Transfers

The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits.  The IRA also increased the amount of existing energy tax credits that are now eligible for sale, such as the...more

Bricker Graydon LLP

IRS Releases Guidance on Elective Payments

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On Wednesday, June 14, 2023, the IRS released its long-awaited initial guidance and proposed regulations regarding the newly created direct payment election methodology. The federal government created this new “elective...more

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