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The One Big Beautiful Bill Act, enacted on July 4, 2025, imposed new restrictions on the availability of the Investment Tax Credit (ITC) and Production Tax Credit (PTC) for wind and solar projects under Code Sections 45Y and...more
On 15 August 2025 the Internal Revenue Service (IRS) released Notice 2025-42 (the Notice), which restricts the methods that developers of wind and solar projects can use to determine whether they have begun construction for...more
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
Enacted in August 2022, the Inflation Reduction Act (the “IRA”) expanded energy tax credits by increasing credit amounts, broadening eligibility beyond wind and solar, and allowing credits to be developed and sold....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, 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, 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
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