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Treasury Circulates Draft Regulations for Section 45Z Clean Fuel Production Credit

A new tax credit is proposed to calculate a fuel’s emissions factor based on its full carbon life cycle of production. Notices 2025-10 and 2025-11 (Notices), released on January 10, 2025, outline the intention of the...more

IRS Finalizes Investment Tax Credit Regulations

The regulations provide important clarity around investment tax credits for biogas property, energy storage, and interconnection costs, and ease proposed aggregation rules for multiple properties. The Internal Revenue...more

After the IRA - A New Financing Landscape

As we pass the first anniversary of the Inflation Reduction Act, the project finance markets are beginning to coalesce around novel financing structures designed to make optimal use of the new tax credit subsidies that the US...more

IRS Issues Initial Rules for Domestic Content Bonus Tax Credits

IRS Notice explains how a renewable energy project may qualify for bonus tax credits by using American-made components. Key Points: ..All project components made primarily of steel or iron that perform a structural...more

IRS Clarifies Rules for Energy Community Bonus Tax Credits

The Notice enables developers and investors to more easily determine the Energy Community status of projects. Key Points: ..The IRS and the Treasury Department have provided tables to assist in determining eligibility...more

IRS Extends Renewables Continuity Safe Harbor

Notice 2021-41 gives renewable energy developers more time to complete their projects and qualify for tax credits. Key Points: ..Developers of PTC- and ITC-eligible renewables projects that began construction in 2016...more

Treasury Finalizes Carbon Capture Tax Credit Regulations

The US Treasury Department and the IRS provided practical administrative rules for the carbon capture and sequestration tax credit. Key Points: ..The IRS finalized the third set of rules in a series of regulatory guidance...more

IRS Gives Offshore Wind and Federal Land Projects More Time to Qualify for Tax Credits

Notice 2021-05 gives renewable energy developers 10 years to complete projects located offshore or on federal land. Key Points: ..Developers of offshore and federal land projects now have 10 years to complete their...more

COVID-19 Tax Relief Package Extends Renewable Power and Carbon Capture Tax Credits

Congress extends tax credits for certain renewables, and expands tax credits for offshore wind and waste energy recovery. Key Points: ..Production tax credits for onshore and offshore wind projects are extended at a 60%...more

Future of Carbon Capture Looks Bright After Treasury Proposes Long-Awaited Regulations

The Treasury Department and the IRS provided practical administrative rules for the carbon capture and sequestration tax credit. Key Points: ..These rules are the third in a series of regulatory guidance issued by the IRS...more

IRS Provides COVID-19 Relief for Renewable Energy Projects

Notice 2020-41 gives renewable energy developers more time to complete projects and eases technical requirements of the 3 ½ month rule. Key Points: ..Developers who started construction in 2016 or 2017 now have five years...more

Carbon Capture Industry Receives Long-Awaited 45Q Tax Credit Guidance

The IRS addressed key commercial and technical issues regarding the development and financing of carbon capture and sequestration projects. Key Points: ..The IRS released the first two of three anticipated guidance...more

New Law Extends Tax Credits For Wind and Other Renewable Power Plants

A favorable outcome for wind and other renewable projects, but solar and storage are left out. Key Points: ..Qualifying wind projects on which construction begins after December 31, 2019 and before January 1, 2021 will...more

Key Considerations for Back-Leverage Financings of Renewable Energy Projects

Lenders making back-levered term loans to wind and solar projects focus on tax equity terms that impact their access to project cash flows and ability to foreclose. Key Points: ..Most operating period term loans to US...more

IRS Issues Welcome Guidance on “Continuity Safe Harbor” for Wind Energy Projects

New rules provide wind developers with additional time to satisfy a critical safe harbor. On December 15, 2016, the Internal Revenue Service (IRS) issued Notice 2017-4, which modifies the “continuity safe harbor” as set...more

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