News & Analysis as of

Energy Sector Internal Revenue Code (IRC) Safe Harbors

Holland & Knight LLP

Beginning of Construction for Solar and Wind Facilities: What's Changed?

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The IRS on Aug. 15, 2025, released Notice 2025-42, which provides guidance on how taxpayers can establish the "beginning of construction" (BOC) of a wind or solar facility for purposes of determining whether such facility is...more

Holland & Knight LLP

Eyes on Energy Tax Update: Second Quarter 2024

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Eyes on Energy Tax Update is a regular publication of the Holland & Knight Renewable and Alternative Energy Tax Team that provides highlights of important developments. The Renewable and Alternative Energy Tax Team also...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release New Safe Harbor Election for Domestic Content Bonus Credits

On May 16, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2024-41 (the Notice), providing further guidance on domestic content bonus credit amounts applicable under...more

Bradley Arant Boult Cummings LLP

Inflation Reduction Act Domestic Content Bonus Update: IRS Issues Updated Guidance with New Elective Safe Harbor

On May 16, 2024, the IRS released Notice 2024-41 (the “Notice”), modifying its preliminary guidance issued last May in Notice 2023-38 addressing the application of potential future rules that taxpayers must satisfy to qualify...more

Holland & Knight LLP

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

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The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

Holland & Knight LLP

Eyes on Energy Tax Update: Second Quarter 2023

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The second quarter of 2023 saw continued developments as a result of the enactment of the Inflation Reduction Act of 2022 (IRA), court activity and announcements from federal agencies. Below, we summarize the updates you need...more

McGuireWoods LLP

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

McGuireWoods LLP on

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

McDermott Will & Schulte

IRS Issues Private Letter Ruling Allowing Tax Equity Financing with a Regulated Utility Taxpayer

In Private Letter Ruling 201946007, the Internal Revenue Service (IRS) allowed a tax equity investor to participate with a regulated utility in a tax equity financing arrangement for wind investments without being subject to...more

King & Spalding

Investments in Renewable and Conventional Power Projects in Qualified Opportunity Zones

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The Qualified Opportunity Zone rules under Section 1400Z of the Internal Revenue Code permit certain investors to realize substantial tax benefits if they invest capital into federally-designated low-income communities known...more

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