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Clean Energy Energy Tax Incentives Internal Revenue Service

A&O Shearman

Highlights of the New Sections 45Y and 48E Wind and Solar Beginning-of-Construction Guidance

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On July 4, 2025, Public Law 119-21, commonly known as the One Big Beautiful Bill Act (the “OBBBA”), became law and enacted significant changes to various renewable energy incentives, including the clean electricity production...more

Vinson & Elkins LLP

Beginning of Construction Guidance Eliminates 5% Safe Harbor (for Wind and Solar), but Physical Work Test Survives

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On August 15, 2025, the Department of Treasury and the Internal Revenue Service (“IRS”) released guidance for wind and solar facilities under Sections 45Y and 48E (the “Tech-Neutral Tax Credits”) in the form of IRS Notice...more

Bracewell LLP

Treasury Department and IRS Issue New Beginning-of-Construction Guidance for Wind and Solar Facilities

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The One Big Beautiful Bill Act (which we discussed in a previous client alert) generally requires wind and solar facilities to begin construction before July 5, 2026, or be placed in service by December 31, 2027, to qualify...more

Holland & Knight LLP

IRS Releases New Beginning of Construction Rules for Clean Energy Tax Credits

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The IRS on Aug. 15, 2025, released Notice 2025-42, which provides new guidance on how taxpayers can establish that they have begun construction of a wind or solar facility for purposes of determining whether such facility is...more

Schwabe, Williamson & Wyatt PC

An Overview of Tech-Neutral Energy Tax Credits for Energy Project ‎Developers

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have published final regulations for the Clean Electricity Investment and Production Tax Credits, also known as technology-neutral energy...more

Buchalter

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

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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

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

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025 #2

The Senate Republicans continue to meet internally and with stakeholders regarding the provisions of a reconciliation package (H.R. 1). Senate Majority Leader John Thune (R-SD) made it clear that the Senate will make...more

Holland & Knight LLP

IRS Issues Updates for Energy Community Bonus Tax Credit

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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

Potomac Law Group, PLLC

5 Ways to Mitigate Challenges to the IRA Energy Tax Credits in 2025

This Tax Alert is the second in a series of monthly alerts that I will issue to discuss tax legislation in 2025 and the outlook for the Inflation Reduction Act (IRA) renewable energy tax incentives. You can find the first Tax...more

Vinson & Elkins LLP

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

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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

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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

Foley Hoag LLP - Energy & Climate Counsel

A Boon for Biogas: Treasury’s Final Section 48 ITC Rules Resolve Key Concerns for Biogas and RNG Projects

On December 4, 2024, the Department of the Treasury finalized new rules governing the Section 48 Investment Tax Credit (“ITC”). The ITC applies to a broad range of clean energy projects, including biogas projects, which were...more

Jones Day

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

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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

DLA Piper

REIT Tax News - November 2024

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Welcome to the November 2024 issue of REIT Tax News. Below, we summarize five key developments impacting REITs this past year....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

Baker Botts L.L.P.

Proposed Regulations Regarding Section 48E Clean Electricity Low-Income Communities Bonus Credit Program

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On September 3, 2024, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) published proposed regulations relating to the Clean Electricity Low-Income Communities Bonus Credit Program (the...more

ASKramer Law

Energy Tax Credits for a New World Part VI: Energy Community Bonus Credits

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What is the purpose of the Energy Community Bonus Credit? The Inflation Reduction Act (IRA) introduced the Energy Community Bonus Credit to encourage renewable energy project developers to locate their facilities and energy...more

ASKramer Law

Energy Tax Credits For A New World Part V: Domestic Content Bonus Credits

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What is the purpose of the Domestic Content Bonus Credit? The Inflation Reduction Act (IRA) introduced the Domestic Content Bonus Credit to provide an additional credit amount to taxpayers that meet its requirements. The...more

Cadwalader, Wickersham & Taft LLP

Everything You Need to Know About Energy Tax Credit Sales

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

DarrowEverett LLP

New Domestic Content Adder Guidance: ‘Buy American’ is Back

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On May 16, 2024, the Department of the Treasury and the IRS announced the release of Notice 2024-41, which clarifies the safe harbor for classification of project components created in Notice 2023-38 and provides a new safe...more

Mayer Brown

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

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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

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