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Client Alert: Reconciliation Bill Passes House: Detailed Analysis of Energy Tax Credit Changes

The House of Representatives has passed a sweeping tax reconciliation bill that makes significant changes to the U.S. energy tax credit regime. The bill, as originally reported out of the House Ways and Means Committee,...more

Final Regulations Released for the Clean Electricity Low-Income Communities Bonus Credit Program

The U.S. Department of the Treasury and the Internal Revenue Service have published final regulations concerning the low-income communities bonus credit program under Section 48E(h) of the Internal Revenue Code of 1986, as...more

New IRS Guidance on Domestic Content Bonus Credit

The U.S. Department of the Treasury and the Internal Revenue Service have issued Notice 2025-08 (the “First Updated Elective Safe Harbor”), offering new guidance on the bonus credit for projects using domestically produced...more

Tech-Neutral Credits Final Regulations Released for Clean Electricity Production

The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) have released final regulations for two new tax credits under the Internal Revenue Code (Code), established by the Inflation Reduction Act...more

Treasury and IRS Release Guidance on Clean Fuel Production Credit

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released a notice of intent to propose regulations and a notice providing the annual emissions rate table for the Clean Fuel...more

Section 45V Clean Hydrogen Tax Credits: Final Regulations Released

The U.S. Department of the Treasury and Internal Revenue Service (IRS) have released final regulations or tax credits for the production of clean hydrogen under Section 45V of the Internal Revenue Code. The industry has...more

Section 48 Energy Investment Tax Credit: Final Regulations Released

The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) have released final regulations for the energy investment tax credit (ITC) under Section 48 of the Internal Revenue Code, which was...more

The Domestic Content Bonus Credit for Renewable Energy Projects: IRS Updates ‘DC Adder’ and Adds Elective Safe Harbor Guidance

The U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have modified a framework relating to renewable energy projects that qualify for the domestic content bonus tax credit (the “DC Adder”)...more

Clean Hydrogen Tax Credits: Treasury Department and IRS Propose Regulations on Production and Investment Tax Credits Under the...

The Treasury Department and IRS have published proposed regulations relating to credits for producing clean hydrogen under the Inflation Reduction Act  (“IRA”), a key step in implementing the National Clean Hydrogen Strategy....more

Prevailing Wage and Apprenticeship Requirements: Treasury Department and IRS Propose Regulations for Clean Energy Projects Under...

The Department of the Treasury and Internal Revenue Service (IRS) published proposed regulations (the “Proposed Regulations”) providing further guidance on the prevailing wage and apprenticeship requirements for clean energy...more

IRS Issues Direct Pay and Transferability Proposed Regulations

On June 14, 2023, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) under two novel provisions of the Inflation Reduction Act of 2022 (the “IRA”) designed to promote capital investment in renewable...more

IRS Guidance on Domestic Content – What Renewable Energy Companies Need to Know

New tax guidance explaining how renewable energy projects can qualify for “bonus credits” if they meet U.S. domestic content rules answers significant questions, but also creates a qualification framework that will be...more

Inflation Reduction Act Levels Renewable Energy Playing Field for Tax-Exempt Entities

Historically, only taxpaying entities could take advantage of federal tax credits for renewable energy and other qualifying projects. Tax-exempt entities, such as municipal utilities and rural electrical cooperatives, as well...more

The Inflation Reduction Act — Incentives for Clean Motor Vehicles and Refueling Property

The Inflation Reduction Act of 2022 (the “IRA”) released by U.S. Senate Democrats on July 27, 2022 would, if enacted, provide a number of financial incentives to encourage the purchase of electric and hydrogen fuel cell...more

IRS Gives 2016‐2020 Vintage Renewable Energy Projects More Time to Finish Construction; Relaxes Continuity Rules

IRS guidance issued June 29, 2021 extends the deadline by which renewable energy projects (including wind and solar projects) that began construction in 2016 through 2020 may finish construction and qualify for production tax...more

IRS Finalizes Guidance Relating to Carbon Capture and Sequestration

On January 6, 2021, the IRS issued final regulations relating to section 45Q. This is the fourth piece of guidance from the IRS relating to section 45Q, following IRS Notice 2020-12, Revenue Procedure 2020-12, the Proposed...more

Energy Taxation: Impact Of The Tax Cuts And Jobs Act

Congress has passed the tax reform bill, known as the "Tax Cuts and Jobs Act", and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law that affect many industries. ...more

The Impact On Energy If The House's "Tax Cuts And Jobs Act" Passes

We drafted a tax alert that addresses the impact of the much anticipated "Tax Cut and Jobs Act" (H.R. 1) on the energy industry. The complete text of the alert is available here. Below is a brief summary of H.R. 1. ...more

IRS Issues Further Guidance on “Start of Construction” Requirement for Renewable Energy Tax Credits, Including Continuity...

On May 5, 2016, the IRS released Notice 2016-31, which provides additional guidance on the “start of construction” requirements for the production tax credit (PTC) and investment tax credit (ITC) in lieu of the PTC. Notice...more

IRS Issues Additional Guidance on "Start of Construction" Requirement for Renewable Energy Tax Credits

On August 8, 2014, the IRS released Notice 2014-46, which provides additional guidance on the "start of construction" requirements for the investment tax credit (ITC) and production tax credit (PTC). As discussed below,...more

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