News & Analysis as of

Energy Tax Incentives Executive Orders

Troutman Pepper Locke

IRS Issues Beginning of Construction Guidance in Response to July Executive Order

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On August 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-42, which provides guidance on the beginning of construction requirement as it relates to the new credit termination...more

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Akin Gump Strauss Hauer & Feld LLP

New BOC Guidance Released

On August 15, 2025, the IRS released new beginning of construction (BOC) guidance for solar and wind facilities claiming production and investment tax credits under sections 45Y and 48E of the Internal Revenue Code in IRS...more

Holland & Knight LLP

Executive Order Requires Treasury Guidance on Wind, Solar and FEOC Rules for Energy Tax Credits

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President Donald Trump issued an executive order (EO) on July 7, 2025, regarding "Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources." The EO follows the signing into law of the One Big...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

Foley & Lardner LLP

Made in the USA - IRA Tax Credits for Renewable Energy Component Manufacturers

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The passage of the Inflation Reduction Act (IRA) this past August saw the introduction of a number of new and expanded tax credits aimed at onshoring American manufacturing...more

Akin Gump Strauss Hauer & Feld LLP

Some Will Always Have Paris: Withdrawal from the Climate Change Accord May Not Reduce the Heat on the Health Care Industry

President Trump’s decision earlier this month to withdraw the United States from the Paris Agreement—an international, nonbinding agreement to take steps to limit global temperature rise—followed a series of moves at the...more

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