News & Analysis as of

One Big Beautiful Bill Act Clean Energy Tax Credits

Akerman LLP

Start of Construction For Solar and Wind Projects in a Post-OBBBA World

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On August 15, 2025, the Treasury Department and the Internal Revenue Service (IRS) released Notice 2025-42 (the Notice) eliminating the safe harbor under which solar and wind projects could establish start of construction by...more

Mayer Brown

IRS Releases Updated OBBBA-Related Energy Credit Guidance

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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

A&O Shearman

Highlights of the New Sections 45Y and 48E Wind and Solar Beginning-of-Construction Guidance

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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

Pierce Atwood LLP

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

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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

Latham & Watkins LLP

Treasury Guidance Narrows Beginning of Construction Rules for Wind and Solar Projects

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Wind and solar projects seeking to begin construction before July 4, 2026, must meet stricter qualification criteria for some tax incentives....more

Paul Hastings LLP

IRS and Treasury Tighten Beginning-of-Construction Rules for Wind and Solar

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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

Jones Day

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

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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

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

Baker Botts L.L.P.

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

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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

Bracewell LLP

Treasury Department and IRS Issue New Beginning-of-Construction Guidance for Wind and Solar Facilities

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The One Big Beautiful Bill Act (which we discussed in a previous client alert) generally requires wind and solar facilities to begin construction before July 5, 2026, or be placed in service by December 31, 2027, to qualify...more

Holland & Knight LLP

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

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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

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

Brownstein Hyatt Farber Schreck

Impacts from the One Big Beautiful Bill Act: A Guide for City Leaders

The One Big Beautiful Bill Act (OBBBA) was signed into law on July 4, 2025. Its primary objective is to extend key provisions of the 2017 Tax Cuts and Jobs Act (TCJA), including individual and corporate tax cuts. Beyond tax...more

Jackson Walker

Key Tax Law Changes Under the One Big Beautiful Bill Act: A Comprehensive Overview

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The One Big Beautiful Bill Act (OBBBA), enacted in 2025, brings sweeping changes to federal tax law, impacting individuals, businesses, investors, and the clean energy sector. Below is a summary of the major updates, with...more

Jones Day

One Big Beautiful Bill Act— Impact on Energy Tax Credits

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The One Big Beautiful Bill Act (the “OBBBA”), which was passed on July 4, 2025, included several changes to the energy tax credits introduced and expanded by the Inflation Reduction Act of 2022 (the “IRA”). The key changes to...more

Jackson Walker

Clean Energy Tax Credit Changes under the One Big Beautiful Bill Act

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The One Big Beautiful Bill Act (the “OBBBA”) limits future opportunities for some of the clean energy tax credits previously enacted under the Inflation Reduction Act of 2022 (the “IRA”). During the election campaign...more

Buchalter

Key Tax Changes in Public Law 119-21: What Individuals and Businesses Need to Know

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On July 4, 2025, the President signed into law Public Law 119-21 (the “Act”). For individuals, the Act makes the tax rate cuts of the 2017 Tax Cuts and Jobs Act (“2017 TCJA”) permanent, and modifies and introduces additional...more

K&L Gates LLP

Navigating the One Big Beautiful Bill Act: Critical Updates to Clean Energy Credits

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President Donald J. Trump signed H.R. 1, the One Big Beautiful Bill Act (OBBBA), into law on 4 July 2025 in an afternoon signing ceremony at the White House (Pub. L. No. 119-21). Senate Majority Leader John Thune (R-SD)...more

Herbert Smith Freehills Kramer

Tax Provisions in the One Big Beautiful Bill Act

On July 4, President Trump signed into law the One Big Beautiful Bill Act (the Act). While the Act covers a wide swath of territory, the core of the Act is its tax provisions. The Act (i) makes permanent many of the tax...more

Husch Blackwell LLP

Recent Developments from the OBBBA and EO 14315: Rush to Begin Construction and Pricing Uncertainty

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As we have discussed in recent articles and as has been well publicized, two recent actions out of Washington are significantly impacting the renewable energy industry. The recently enacted One, Big, Beautiful Bill Act...more

Jackson Walker

Carbon Oxide Sequestration Tax Credit Changes Under the One Big Beautiful Bill Act

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The One Big Beautiful Bill Act (the “OBBBA”) modifies the federal income tax credit for carbon oxide sequestration. Such tax credit, in place since 2008, was previously increased by the Inflation Reduction Act of 2022....more

Husch Blackwell LLP

Understanding the OBBBA’s FEOC Framework

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The One Big Beautiful Bill Act (OBBBA), signed into law by President Donald Trump on July 4, 2025, provides for enhanced restrictions on entities claiming many of the renewable energy credits established under the Inflation...more

McCarter & English, LLP

One Big Beautiful Bill Act Tax Law Updates—Energy Sector

On July 4, 2025, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA) (P.L. 119-21), which includes a number of tax law changes that directly impact the energy industry. A significant number of the...more

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