On June 18, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Regulations) on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing...more
On June 7, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-48. This notice includes lists of information that taxpayers may use to determine whether they meet certain requirements...more
On May 16, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-41, which modifies Notice 2023-38 (Prior Guidance) by expanding the list of Applicable Projects (defined below) to...more
5/23/2024
/ Energy Projects ,
Energy Storage ,
Hydropower ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Investment Tax Credits ,
IRS ,
Manufacturers ,
Natural Gas ,
Oil & Gas ,
Proposed Regulation ,
Renewable Energy ,
Safe Harbors ,
U.S. Treasury
On April 25, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on tax credit transfers pursuant to Section 6418 of the Internal Revenue Code of 1986, as...more
On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore...more
On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the...more
3/11/2024
/ Energy Projects ,
Final Rules ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Tax Credits ,
Tax Liability ,
U.S. Treasury
The IRS announced on December 22, 2023, that it has launched the pre-filing registration portal for direct payments under Section 6417 and tax credit transfers under Section 6418....more
The IRS and the Treasury Department issued proposed regulations on December 26, 2023 (Proposed Regulations), providing guidance on the clean hydrogen production tax credit under Section 45V (Hydrogen PTC) and the investment...more
1/2/2024
/ Clean Energy ,
Climate Action Plan ,
Department of Energy (DOE) ,
Energy Projects ,
Energy Tax Incentives ,
Greenhouse Gas Emissions ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Proposed Regulation ,
Regulatory Agenda ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
On December 14, the Department of the Treasury and the Internal Revenue Service (IRS), issued proposed regulations providing guidance on the Advanced Manufacturing Production Credit (Section 45X Credit), established by the...more
On December 1, the U.S. Department of Energy (DOE) released long-awaited proposed guidance defining “foreign entity of concern” (FEOC) under the Infrastructure Investment and Jobs Act (IIJA). Simultaneously, the U.S....more
12/14/2023
/ Automotive Industry ,
China ,
Clean Car Standards ,
Clean Energy ,
Department of Energy (DOE) ,
Electric Vehicles ,
Foreign Entities ,
Inflation Reduction Act (IRA) ,
Infrastructure Investment and Jobs Act (IIJA) ,
IRS ,
Motor Vehicles ,
Proposed Guidance ,
Subsidies ,
Supply Chain ,
Tax Credits ,
U.S. Treasury
The IRS and the Treasury Department issued proposed regulations under Section 48 on November 22, 2023 (Proposed Regulations), providing further guidance in determining whether property is energy property and eligible for the...more
The Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing Wage Requirements) and (8)...more
On June 20, the U.S. Court of Federal Claims issued an opinion and order, denying plaintiffs’ motion for summary judgment in Alta Wind I Owner-Lessor C, et al. v. U.S. (Nos. 13-402, 13-917, 13-935, 13-972, 14-47, 14-93,...more
On June 14, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations and temporary regulations on direct pay of certain tax credits pursuant to Section 6417 of the Internal Revenue...more
On June 15, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-45 and Notice 2023-47. Notice 2023-45 clarifies requirements for a brownfield site energy community safe harbor provided...more
6/20/2023
/ ASTM ,
Brownfield Properties ,
Coal Industry ,
Contaminated Properties ,
Energy Projects ,
Environmental Site Assessment ,
Inflation Reduction Act (IRA) ,
IRS ,
Safe Harbors ,
Tax Liability ,
U.S. Treasury
On June 14, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations and temporary regulations on tax credit transfers pursuant to Section 6418 of the Internal Revenue Code of...more
On May 12, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-38, which describes certain rules that Treasury and the IRS intend to include in forthcoming proposed regulations...more
The availability of transferable tax credits brings opportunities for an investor to reduce tax burden, while also facilitating investments in renewables. How can dealmakers best unlock the potential value that awaits, while...more
Introduction -
On March 31, the Internal Revenue Service (IRS) issued highly anticipated proposed regulations on electric vehicle (EV) tax credits. Driven by an ambitious climate agenda, the Biden administration has...more
On April 4, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-29, which describes certain rules that Treasury and the IRS intend to include in forthcoming proposed regulations...more
On Aug. 16, President Joe Biden signed the Inflation Reduction Act into law. The legislation includes landmark tax incentives for domestic energy production and manufacturing, with the goal of reducing carbon emissions in the...more
Today, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published Notice 2022-61, providing guidance on the prevailing wage requirements under Section 45(b)(7)(A) and substantially similar provisions...more
On August 16, President Biden signed the Inflation Reduction Act of 2022 (IRA) into law, which includes landmark tax incentives for domestic energy production and manufacturing with the goal of reducing carbon emissions in...more
Wind and Solar PTC and specified § 45 technologies -
100% of PTC rate (assuming labor requirements met)
...more
I. Introduction -
President Biden signed the Inflation Reduction Act of 2022 (IRA) into law on August 16, as we provided in our extensive summary. The IRA includes landmark investment opportunities in domestic energy...more