4 Key Takeaways | Harnessing the Inflation Reduction Act: Driving Investments in Renewable Energy and Carbon Reduction
The Capacity Crunch, Part Three: Unpacking the Power of the IRA: The Potential Game-Changing Opportunities for Utilities - Energy Law Insights
Analyzing the Impact of the IRA on Energy Storage — Battery + Storage Podcast
Renewable Natural Gas – The Next Frontier
The Challenges and Opportunities of Interconnection and Transmission of Renewable Energy
Tax Issues for Co-location of Energy Storage with Solar or Wind
Monetizing Opportunities in Energy Storage in a Post-IRA World
Optimizing Investments in Energy Storage
Value Creation in the Transferable Tax Market
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
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
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
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
On August 15, the Treasury Department published long-awaited guidance on applicability of “beginning of construction” safe harbors for solar and wind projects under the One Big Beautiful Bill and Executive Order 14315. While...more
Following the release of energy community bonus credit and low-income community bonus credit guidance, the U.S. Department of the Treasury and IRS recently provided taxpayers with the domestic content bonus credit guidance....more
On June 29, 2021, the IRS released Notice 2021-41 (the Notice) extending the length of the Continuity Safe Harbor (as defined below) for purposes of claiming the investment tax credit (ITC) or the production tax credit (PTC)....more
On June 29, 2021, the IRS issued Notice 2021-41, which provides a further extension of the continuity safe harbor and revises the “facts and circumstances” rules: ..For PTC and ITC-eligible projects for which...more
Renewable energy developers breathed a sigh of relief Tuesday when the Internal Revenue Service and Department of the Treasury issued guidance extending the safe harbor for wind and solar projects to qualify for the...more
On May 27, 2020, the IRS issued Notice 2020-41, which responds to industry-wide supply chain disruptions due to the COVID-19 pandemic by giving renewable energy developers additional time to complete their projects. Most...more
On May 27, 2020, the US Internal Revenue Service (the “IRS”) released Notice 2020-41 (the “Notice”), updating the IRS guidance on the start-of-construction rules for the production tax credit (“PTC”) and energy investment tax...more
The Internal Revenue Service (IRS) recently released Notice 2020-41 (the Notice), providing important relief with respect to the beginning-of-construction requirement for the production tax credit (PTC) and the investment tax...more
IRS Notice 2020-41 provides relief for renewable energy projects that began construction in 2016 or 2017 by extending the “continuity safe harbor” to a five-year period....more
In a May 21 letter to Treasury Secretary Steven Mnuchin, three Republican senators—Senator Lisa Murkowski (R-AK), Senator Susan M. Collins (R-ME), and Senator Thom Tillis (R-NC)—have requested that Treasury modify existing...more
In a letter addressed to Senator Chuck Grassley, Chairman of the Senate Committee on Finance, Treasury indicates its intention to revise the rules governing the deadline for construction of wind and solar projects to qualify...more
Background - As the COVID-19 pandemic continues to disrupt project development timelines generally, solar and wind projects that rely on federal income tax credits to obtain financing are particularly sensitive to...more
The IRS recently issued Notice 2018-59 (the “Notice”) which provides clarification to “beginning of construction” for taxpayers seeking to take advantage of the section 48 renewable electricity investment tax credit (ITC) for...more
Solar developers are getting antsy about what is needed to show that they started construction on their 2020 (or later) projects by the end of 2019. The answer is not clear in the absence of solar-specific guidance from...more
On December 15, 2016, the Internal Revenue Service released Notice 2017-04, which provides welcome guidance on how to meet the “beginning of construction” requirements for wind and other qualified facilities. There has been...more
On May 5, 2016, the IRS released Notice 2016-31, which provides additional guidance on the “start of construction” requirements for the production tax credit (PTC) and investment tax credit (ITC) in lieu of the PTC. Notice...more
The IRS recently issued Notice 2016-31, providing further guidance regarding the “beginning of construction” requirement for the production tax credit (PTC) under Section 45 of the Internal Revenue Code and the investment tax...more
On May 5, 2016, the Internal Revenue Service (IRS) issued Notice 2016-31, providing guidance on meeting the beginning of construction requirements for wind and other qualified facilities (including biomass, geothermal,...more
Latest guidance extends “continuity safe harbor” to four years and includes other taxpayer-friendly modifications and clarifications to existing guidance. On May 5, 2016, the Internal Revenue Service (IRS) issued...more
On May 5, 2016, the IRS issued Notice 2016-31 (the “Notice”) which revises previous guidance on satisfying the “beginning of construction” test in order to take advantage of the section 45 renewable electricity production tax...more
On Friday, the IRS issued a heavily redacted Chief Counsel Advice (CCA) memorandum, which addresses the intersection of solar investment tax credit partnership flip transactions and the wind production tax credit partnership...more