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Renewable Energy Solar Energy Internal Revenue Service

Holland & Hart LLP

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

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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

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

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

DLA Piper

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

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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

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

Offit Kurman

Navigating the New Construction Timing Rules for Wind and Solar Tax Credits

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The renewable energy sector faces significant regulatory changes following the enactment of the One Big Beautiful Bill Act (OBBBA) on July 4, 2025. Through IRS Notice 2025-42, issued under Executive Order 14315, the Treasury...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

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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

Davis Wright Tremaine LLP

IRS Makes It More Difficult for Solar and Wind Facilities to Qualify for Federal Tax Credits

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

Eversheds Sutherland (US) LLP

New Beginning of Construction Guidance Related to the Termination of Wind and Solar Renewable Energy Tax Credits Under the OBBBA

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

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

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

DarrowEverett LLP

Get to Work: New Treasury Guidance Changes Safe Harbors for Solar and Wind Tax Credits

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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

Foley & Lardner LLP

Treasury Releases New Beginning of Construction Guidance for Wind and Solar

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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

White & Case LLP

New Law Changes IRA Tax Credits - Update

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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

Pullman & Comley, LLC

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

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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

Husch Blackwell LLP

New Executive Order Targets Wind and Solar Tax Credits

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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

Troutman Pepper Locke

Tax Credit Implications of the One Big Beautiful Bill Act

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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

DarrowEverett LLP

The Forecast Calls For Sun: What New Administration's First 30 Days Means for Solar Industry

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United States policy surrounding renewable energy has fluctuated significantly as administrations change; President Jimmy Carter put solar panels on the White House in 1978, and President Ronald Reagan removed the panels in...more

Bradley Arant Boult Cummings LLP

Inflation Reduction Act Domestic Content Bonus Update: IRS Issues Updated Guidance with First Updated Elective Safe Harbor

On January 16, 2025, the IRS released Notice 2025-08, modifying its prior guidance issued as Notice 2023-38 and Notice 2024-41, for taxpayers seeking to qualify for the domestic content bonus tax credit amounts under the...more

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