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IRS Issues Proposed Rules on New Tech-Neutral Clean Energy PTC and ITC

On May 29, 2024, the Internal Revenue Service (IRS) and the Department of Treasury issued proposed regulations (REG-119283-23) addressing the new technology neutral clean electricity production tax credit (PTC) in section 45Y...more

IRS Updates PTC and ITC Domestic Content Bonus Guidance

On May 16, 2024, the Internal Revenue Service (IRS) issued further guidance (Notice 2024-41, the Additional Notice) intended to provide clarity and certainty surrounding the domestic content1 bonus credit by (among other...more

The Road Ahead for Private Equity: Energy Transition

The energy transition posts a tremendous opportunity for private equity investors. The scale of the investment requirement makes private capital a “must have” and a broad spectrum of energy transition opportunities,...more

The Road Ahead for Private Equity: Reflections and Predictions

The year 2023 will be remembered as a challenging one for private equity (PE), with complexities to navigate on many fronts. Traditional debt financing was expensive and scarce, expectations on valuations were tricky to...more

Proposed Clean Hydrogen Guidance: Limitations on Credit Availability for Green Hydrogen Projects and Paths Forward

Guidance recently issued by the Department of the Treasury and the Internal Revenue Service (IRS) in proposed regulations (REG-117631-23) will (if held to be final) have a significant impact on green hydrogen projects in the...more

Clean Vehicle Tax Credit – Foreign Entity of Concern Rules Proposed

On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more

Trailblazer Pipeline Company LLC One Step Closer to Transporting Carbon Dioxide Following FERC Order

On October 23, 2023, the Federal Energy Regulatory Commission (FERC) issued an order that will permit Trailblazer Pipeline Company LLC (Trailblazer) to convert its approximately 400-mile-long natural gas pipeline system to...more

Clean Energy Tax Credit Transferability Guidance Issued

On June 14, 2023, the Internal Revenue Service and the Treasury Department issued (among other guidance) an expansive set of proposed regulations explaining how taxpayers can monetize 11 green energy tax credits through...more

Proposed Regulations for Low-Income Community Solar/Wind Tax Credit Introduce New Priority Criteria

On May 31, the Treasury Department issued proposed regulations (REG-110412-23) detailing how small solar and wind facilities located in or connected to low-income communities (LIC) can qualify for the so-called Low-Income...more

PTC and ITC Domestic Content Bonus Guidance Issued

A reasonable analysis of the Buy America standards for manufactured products would have resulted in the qualified facility or energy project being treated as the end product. One would then check to see if the components of...more

Autonomous Systems & Advanced Mobility: 2023 Trends & Predictions

The Autonomous Systems & Advanced Mobility (ASAM) space is headed for more change in 2023, generating new opportunities and challenges for a growing list of industry players. The adoption of new, complex and connected...more

EPA Announces Intent to Approve Class VI Primacy for Louisiana

The U.S. Environmental Protection Agency (EPA) announced its intent to approve the State of Louisiana’s request to take primary responsibility for the permitting of geologic carbon sequestration facilities as Class VI...more

Treasury Updates Guidance Issued Last Week on 'Energy Community' Tax Credit Adders

Summary - On April 4, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) released guidance on the “energy community” tax credit adders (EC Adders) that were added under the Inflation Reduction Act...more

IRS Publishes Initial Guidance on Section 48C(e) Advanced Energy Project Tax Credit

The Internal Revenue Service (IRS) released its initial guidance (the Advanced Energy Project (AEP) Notice, Notice 2023-18) establishing procedures for taking advantage of the renewed and expanded qualifying advanced energy...more

Low-Income Community Solar/Wind Facility Tax Credit Guidance Leaves Most Important Questions Open

While the Internal Revenue Service (IRS) may have nominally satisfied the 180-day deadline in the Inflation Reduction Act (IRA) to establish procedures for taking advantage of special rules applicable to small solar and wind...more

IRS Publishes Initial Guidance on Wage and Apprenticeship Requirements

The Internal Revenue Service (IRS) released its eagerly-anticipated guidance (the PWA Notice) regarding the prevailing wage and apprenticeship requirements under the Inflation Reduction Act (IRA). The publication of the PWA...more

Highlights of DOE’s Historic Clean Hydrogen Funding Opportunity

The U.S. Department of Energy (DOE or the “Department”) recently opened the submission of Concept Papers for its $7 billion H2Hubs program, marking one of the largest investments in DOE history, with the goal of creating up...more

IRS Issues Request for Public Comment on Clean Energy and Climate Provisions Included in Inflation Reduction Act

On October 5, 2022, the Department of Treasury and Internal Revenue Service (IRS) released six Notices requesting comments on anticipated regulations and other guidance under various climate and clean energy incentives...more

President Biden Signs the Inflation Reduction Act

Today, President Biden signed the Inflation Reduction Act of 2022 (IRA) into law. The final IRA bill came together after more than 18 months of intra-party negotiations among Democrats about what legislative priorities to...more

Inflation Reduction Act Update

The following alert provides a high level update to the August 4 Akin Gump comprehensive section-by-section report, which was published before the Senate vote-a-rama and final Senate passage. This update is being published...more

Comprehensive Section-By-Section of the Inflation Reduction Act

Sens. Joe Manchin (D-WV) and Chuck Schumer (D-NY) shocked Washington, D.C. when they announced an agreement around a budget reconciliation package that includes clean energy and health care provisions and tax reform. The...more

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