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In response to Executive Order 14315 (July 7, 2025) (the “July 7 EO”), the IRS released Notice 2025-42 on August 15, 2025. Notice 2025-42 provides rules on how to begin construction for purposes of the effective dates of the...more
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
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
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
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 (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
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
The IRS has made it harder for solar and wind projects to satisfy the beginning of construction rules for purposes of qualifying for federal tax credits....more
On August 15, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued much-anticipated guidance (Notice 2025-42) regarding the determination of when an applicable wind or solar facility is...more
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
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
Treasury and the IRS today released guidance, Notice 2025-42 (the “Notice”), regarding what constitutes beginning of construction for solar and wind energy projects with respect to the production tax credit under Section 45Y...more
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
On June 23, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-31. This notice includes lists of information that taxpayers may use to determine whether they meet certain requirements...more
The U.S. Department of the Treasury and IRS released initial guidance on Jan. 10, 2025, regarding the production tax credit (PTC) for clean fuels under Section 45Z of the Internal Revenue Code, as enacted by the Inflation...more
The U.S. Internal Revenue Service ("IRS") has released proposed regulations regarding the Clean Hydrogen Production Tax Credit introduced in the Inflation Reduction Act of 2022 ("IRA"). The proposed regulations provide more...more
The U.S. Department of the Treasury and IRS released Notice 2024-49 on May 31, 2024, regarding the registration requirement and certain other limited guidance under Section 45Z of the Internal Revenue Code. Section 45Z...more
The IRS issued Notice 2024-41 on May 16, 2024, which provides updated guidance regarding the domestic content bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The new notice modifies previously...more
The IRA created substantial tax credits for SAF. Under Section 40B, SAF producers who meet certain requirements can claim a credit of at least $1.25 per gallon of SAF. Among other things, eligible SAF must achieve lifecycle...more
On April 10, 2024, Department of Treasury and the Internal Revenue Service (collectively, “IRS”) issued further guidance on the “Provisional Emission Rate” or “PER” process for the Inflation Reduction Act’s (“IRA”) Hydrogen...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
The trajectory of the hydrogen sector in the United States hinges on a critical question: what criteria will be used to define the term “clean hydrogen” for tax purposes? As previously outlined in our Field Guide to Clean...more
The Inflation Reduction Act (IRA), which recently celebrated its one-year anniversary, presents new opportunities for tax-exempt and other organizations to directly benefit from renewable energy tax credits, including...more
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
Summary - The IRS recently released guidance with respect to the new tax credit direct payment and transferability rules created under the Inflation Reduction Act enacted last August. The guidance explains how to register...more