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Clean Energy One Big Beautiful Bill Act

Mayer Brown Free Writings + Perspectives

What the New Foreign Entity Rules Mean for Debt Financing When Clean Energy Tax Credits Are at Play

The U.S. government has been steadily tightening rules relating to who can benefit from clean energy incentives.  The One Big Beautiful Bill Act (OBBBA) is the latest step, and it makes one thing crystal clear:  if your...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, Sept. 2025

Congress Weighs FY2026 Funding for IRS, OECD and DOJ Tax Division: As Congress returns this week, lawmakers face a four-week window to resolve differences over government funding for fiscal year 2026 (FY2026). This includes...more

Spilman Thomas & Battle, PLLC

Currents - Energy Industry Insights: V 9, Issue 8, 2025

Welcome to our eighth issue of Currents 2025. Extending the Lives of Fossil Fuel Power Plants Based on Arguably Tenuous Assumptions May Increase Power Prices - In July, the Trump administration’s Department of Energy (DOE)...more

Frost Brown Todd

Shifting Ground: How IRS Notice 2025-42 Redefines When Construction Begins for Applicable Wind and Solar Facilities

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On August 15, 2025, the Internal Revenue Service (IRS) released Notice 2025-42, consistent with President Trump’s recent Executive Order 14315 (EO 14315), which changes how applicable wind and solar facilities establish the...more

Hogan Lovells

U.S. Treasury releases New Beginning of Construction guidance on clean energy tax credits

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With an effective date of September 2, 2025, New Beginning of Construction guidance will be prospective and not apply to projects that satisfied beginning of construction under old IRS guidance before September 2, 2025. ...more

Pillsbury - Gravel2Gavel Construction & Real...

The 2025 Legal Horizon for U.S. Offshore Wind

In its first nine months, the Trump administration has taken multiple actions impacting offshore wind development and generating substantial uncertainty as to the industry’s future in the United States. Those actions have...more

Akerman LLP

Start of Construction For Solar and Wind Projects in a Post-OBBBA World

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On August 15, 2025, the Treasury Department and the Internal Revenue Service (IRS) released Notice 2025-42 (the Notice) eliminating the safe harbor under which solar and wind projects could establish start of construction by...more

Mayer Brown

IRS Releases Updated OBBBA-Related Energy Credit Guidance

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On August 15, 2025, the US Department of the Treasury and the Internal Revenue Service (the “IRS”) issued Notice 2025-42 (the “August 2025 Notice”), providing critical guidance on the determination of when construction begins...more

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

Pierce Atwood LLP

IRS Issues New Beginning of Construction Guidance for Solar and Wind Facilities

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On August 15, 2025, the Internal Revenue Service (IRS) issued Notice 2025-42 to address the beginning of construction (BOC) requirements for solar and wind projects under sections 45Y and 48E of the Internal Revenue Code...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of August 18, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

Latham & Watkins LLP

Treasury Guidance Narrows Beginning of Construction Rules for Wind and Solar Projects

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Wind and solar projects seeking to begin construction before July 4, 2026, must meet stricter qualification criteria for some tax incentives....more

Paul Hastings LLP

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

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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

Jones Day

New "Beginning of Construction" Guidelines Issued for Wind and Solar Tax Credits

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The Internal Revenue Service ("IRS") has issued Notice 2025-42 to implement the One Big Beautiful Bill Act ("OBBBA") mandate to phase out the clean electricity production tax credit (§ 45Y) and investment tax credit (§ 48E)...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

Baker Botts L.L.P.

Clean Energy Tax Credits: New Guidance on Beginning of Construction for Wind and Solar Facilities

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On August 15, 2025, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released new guidance on the “beginning of construction” for wind and solar facilities under the clean electricity...more

Husch Blackwell LLP

Treasury Guidance Tightens "Beginning of Construction" Standards for Clean Energy Tax Credits, Eliminating 5% Safe Harbor for Wind...

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On August 15, 2025, the Internal Revenue Service (IRS) issued Notice 2025-42, providing long-awaited guidance on the “beginning of construction” requirements for wind and solar facilities under Sections 45Y and 48E of the...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

McGuireWoods LLP

IRS Notice 2025-42 Leaves Beginning of Construction Guidance for Wind and Solar Mostly Unchanged, But Limits 5% Safe Harbor to...

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On Aug. 15, 2025, the U.S. Internal Revenue Service issued Notice 2025-42 addressing the beginning of construction for wind and solar facilities under Section 45Y and 48E of the Internal Revenue Code of 1986, as amended. The...more

Stoel Rives LLP

IRS Issues Guidance Regarding Beginning of Construction Requirement for PTC and ITC

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The IRS today issued guidance regarding the “beginning of construction” requirement as it relates to the clean electricity production tax credit (PTC) under Internal Revenue Code Section 45Y and the clean electricity...more

Womble Bond Dickinson

The One Big Beautiful Bill: A Bonus for Equipment Finance

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The One Big Beautiful Bill Act was signed into law by President Donald Trump on July 4, 2025. The OBBB offers material benefits to the players in the equipment finance industry including lessors, lessees, lenders, borrowers,...more

Brownstein Hyatt Farber Schreck

Impacts from the One Big Beautiful Bill Act: A Guide for City Leaders

The One Big Beautiful Bill Act (OBBBA) was signed into law on July 4, 2025. Its primary objective is to extend key provisions of the 2017 Tax Cuts and Jobs Act (TCJA), including individual and corporate tax cuts. Beyond tax...more

Foley Hoag LLP - Energy & Climate Counsel

After the One Big Beautiful Bill Act, Could C-PACE for C&I Solar have its Moment in the Sun?

The recent passage of the One Big Beautiful Bill Act (OBBBA) has introduced significant hurdles to obtaining the tax equity financing upon which solar developers have traditionally relied. As the industry seeks to adapt to...more

Jackson Walker

Key Tax Law Changes Under the One Big Beautiful Bill Act: A Comprehensive Overview

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The One Big Beautiful Bill Act (OBBBA), enacted in 2025, brings sweeping changes to federal tax law, impacting individuals, businesses, investors, and the clean energy sector. Below is a summary of the major updates, with...more

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