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Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
Wind and solar projects seeking to begin construction before July 4, 2026, must meet stricter qualification criteria for some tax incentives....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, 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
This is an updated version of the alert published on July 4. President Trump signed H.R.1, commonly referred to as the "One Big Beautiful Bill Act" (the "Act") into law on July 4, 2025. Below are our summaries of the...more
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
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
In this alert, which is part of an eight-part series taking a deeper dive into various portions of the Legislation (International Tax; Opportunity Zone and Tax Credits; Green Energy Credits; Estate Planning and Individual Tax...more
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
Over the July 4th holiday, President Trump signed H.R. 1 (a/k/a the “One Big Beautiful Bill”) into law (Public Law No: 119-21, the “Act”). This sweeping piece of legislation significantly rolls back clean energy tax credits...more
The One Big Beautiful Bill Act (“OBBB”), which was signed by President Donald Trump on July 4, 2025, revokes or curtails the majority of energy credits and significantly curtails other credits. ...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law, significantly revising the U.S. tax code to reflect the Administration’s domestic energy, trade, and national security priorities. Among...more
The U.S. Environmental Protection Agency (“EPA”) has recently proposed a new rule and the U.S. Congress has recently enacted a new law affecting the global renewable fuel industry....more
President Trump last week signed into law the One Big Beautiful Bill Act (the “Act”). The Act made a number of changes to the clean electricity production credit under Section 45Y of the Internal Revenue Code (the “PTC”), the...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 July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (the OBBB), which significantly rolls back many of the core tax incentives that clean energy projects have relied on since the passage of the...more
On July 7, 2025, President Trump signed the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources.” The EO directs the Secretary of the Treasury to “strictly enforce” the...more