News & Analysis as of

Internal Revenue Service Renewable Energy Internal Revenue Code (IRC)

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
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

Frost Brown Todd

Shifting Ground: How IRS Notice 2025-42 Redefines When Construction Begins for Applicable Wind and Solar Facilities

Frost Brown Todd on

On August 15, 2025, the Internal Revenue Service (IRS) released Notice 2025-42, consistent with President Trump’s recent Executive Order 14315 (EO 14315), which changes how applicable wind and solar facilities establish the...more

Hogan Lovells

U.S. Treasury releases New Beginning of Construction guidance on clean energy tax credits

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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

McDermott Will & Schulte

IRS roundup: August 12 – August 20, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 12, 2025 – August 20, 2025. August 15, 2025: The IRS issued Notice 2025-42, providing guidance consistent with...more

Pullman & Comley, LLC

DEEP Issues Draft Request for Proposals from Private Developers of Zero Carbon Energy Using Onshore Wind, Solar and Co-located...

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On August 21, 2025, the Connecticut Department of Energy & Environmental Protection (DEEP) released an expedited draft Request for Proposals (RFP). The RFP seeks submissions from project developers for new, advanced-stage...more

Flaster Greenberg PC

IRS Issues New Guidance For Renewable Energy Tax Credits

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The IRS continues to issue guidelines regarding the tax credit provisions of Sections 45Y and 48E of the Internal Revenue Code, as amended (IRC). The latest notice was issued as Notice 2025-42 on Aug. 15, 2025 (Notice)...more

Holland & Hart LLP

Termination Effectiveness Beginning (Of Construction): Notice 2025-42

Holland & Hart LLP on

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

Pierce Atwood LLP

IRS Issues New Beginning of Construction Guidance for Solar and Wind Facilities

Pierce Atwood LLP on

On August 15, 2025, the Internal Revenue Service (IRS) issued Notice 2025-42 to address the beginning of construction (BOC) requirements for solar and wind projects under sections 45Y and 48E of the Internal Revenue Code...more

DLA Piper

IRS Releases Guidance on Wind and Solar Facility Tax Credits: Key Takeaways

DLA Piper on

The US Department of the Treasury and the Internal Revenue Service (IRS) recently released Notice 2025-42 to implement Executive Order (EO) 14315. The Notice, issued on August 15, 2025, provides guidance on when construction...more

Jones Day

New "Beginning of Construction" Guidelines Issued for Wind and Solar Tax Credits

Jones Day on

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

Baker Botts L.L.P.

Clean Energy Tax Credits: New Guidance on Beginning of Construction for Wind and Solar Facilities

Baker Botts L.L.P. on

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

Husch Blackwell LLP

Treasury Guidance Tightens "Beginning of Construction" Standards for Clean Energy Tax Credits, Eliminating 5% Safe Harbor for Wind...

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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

Holland & Knight LLP

IRS Releases New Beginning of Construction Rules for Clean Energy Tax Credits

Holland & Knight LLP on

The IRS on Aug. 15, 2025, released Notice 2025-42, which provides new guidance on how taxpayers can establish that they have begun construction of a wind or solar facility for purposes of determining whether such facility is...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

McGuireWoods LLP

IRS Notice 2025-42 Leaves Beginning of Construction Guidance for Wind and Solar Mostly Unchanged, But Limits 5% Safe Harbor to...

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On Aug. 15, 2025, the U.S. Internal Revenue Service issued Notice 2025-42 addressing the beginning of construction for wind and solar facilities under Section 45Y and 48E of the Internal Revenue Code of 1986, as amended. The...more

Stoel Rives LLP

IRS Issues Guidance Regarding Beginning of Construction Requirement for PTC and ITC

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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

Schwabe, Williamson & Wyatt PC

An Overview of Tech-Neutral Energy Tax Credits for Energy Project ‎Developers

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

Pullman & Comley, LLC

DEEP Issues Request for Information to Inform Expedited Request for Proposals – IMMEDIATE ACTION NEEDED

Pullman & Comley, LLC on

The Connecticut Department of Energy & Environmental Protection (DEEP) released a Request for Information late Friday seeking “expressions of interest from potential project developers who believe that they can (1) meet the...more

Holland & Knight LLP

IRS Releases 2025 Inflation Adjustments for Sections 45U, 45V and 45Z

Holland & Knight LLP on

The IRS on July 21, 2025, released Notice 2025-37, announcing the inflation-adjusted credit amounts for calendar year 2025 applicable to tax credits available under Internal Revenue Code Sections 45U, 45V and 45Z, which were...more

Baker Botts L.L.P.

The "One Big Beautiful Bill Act" Substantially Alters Clean Energy Tax Landscape

Baker Botts L.L.P. on

On July 4, 2025, the legislation commonly known as the "One Big Beautiful Bill Act" (the “BBBA”) was enacted. The BBBA makes significant changes to the tax credits available under the Inflation Reduction Act of 2022 (the...more

Holland & Knight LLP

IRS Issues Updates for Energy Community Bonus Tax Credit

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The IRS released additional guidance on June 23, 2025, in the form of Notice 2025-31 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...more

Troutman Pepper Locke

Tax Credit Implications of the One Big Beautiful Bill Act

Troutman Pepper Locke on

On May 22, the U.S. House of Representatives passed an amended version of H.R. 1—the One Big Beautiful Bill Act (the Bill) — by a vote of 215-214. The House-passed version of the bill, slated to be considered by the Senate...more

Holland & Knight LLP

Eyes on Energy Tax: IRS Releases 2025 Section 45 Production Tax Credit Amounts

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The IRS on May 23, 2025, released 2025 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code. The guidance provides that: Section 45 allows a renewable energy PTC for generating electricity from...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Implementation of Section 45Z/Clean Fuels Production Credit: Energy Marketers of America Comments on Internal Revenue Service's...

The Energy Marketers of America (formerly, Petroleum Marketers Association of America) (“EMA”) submitted April 10th comments to the Internal Revenue Service (“IRS”) addressing its: …notice of intent to propose regulations...more

Beveridge & Diamond PC

Key Areas for Regulatory Engagement With the Trump Administration’s Emphasis on Biofuels

Overview - Among its energy policy priorities, early executive orders, and other actions, the Trump administration has reinforced its commitment to expanding the U.S. biofuels sector, which typically has strong bipartisan...more

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