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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
Wind and solar projects seeking to begin construction before July 4, 2026, must meet stricter qualification criteria for some tax incentives....more
The renewable energy sector faces significant regulatory changes following the enactment of the One Big Beautiful Bill Act (OBBBA) on July 4, 2025. Through IRS Notice 2025-42, issued under Executive Order 14315, the Treasury...more
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
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
On July 4, 2025, President Donald Trump signed into law the One Big Beautiful Bill Act, following its passage out of the U.S. Senate by the slimmest of margins (51-50) requiring the vote of the Vice President to break the...more
On May 22, 2025, the House passed the legislation entitled “The One Big Beautiful Bill” (the “BBB”) that would, if enacted into law, severely restrict clean energy tax incentives. This client update addresses the BBB’s...more
On December 4, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations providing further guidance in determining whether property is energy property and eligible for the Investment...more
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
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
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
Proposed tax regulations to be released this year may clarify whether agricultural land contaminated with per- and polyfluoroalkyl substances (PFAS) qualify for a federal tax credit that would incentivize renewable energy...more
The Treasury Department and IRS recently issued final regulations on the transfer of certain credits to implement the transferability provisions of the Inflation Reduction Act (IRA), which take effect on July 1, 2024....more
The U.S. Department of the Treasury (Treasury) today released Notice 2024-41, Domestic Content Bonus Credit Amounts under the Inflation Reduction Act of 2022: Expansion of Applicable Projects for Safe Harbor in Notice 2023-38...more
On April 25, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for...more
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
On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore...more
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
The IRS and the Treasury Department issued proposed regulations on December 26, 2023 (Proposed Regulations), providing guidance on the clean hydrogen production tax credit under Section 45V (Hydrogen PTC) and the investment...more
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
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
The proposed regulations offer helpful guidance for taxpayers seeking to take advantage of the ITC under IRC section 48. The proposed regulations add new definitions to clarify the scope of recently added qualifying...more
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
The U.S. Department of the Treasury (Treasury Department) recently released a notice of proposed rulemaking regarding four significant aspects of the investment tax credit (ITC) under Section 48 of the Internal Revenue Code...more
The U.S. Department of the Treasury (Treasury) today released a notice of proposed rulemaking (Proposed Regulations) related to the prevailing wage and apprenticeship (PWA) requirements for increased tax credits established...more