On June 14, 2023, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released temporary regulations (Temporary Regulations) and proposed regulations (Proposed Regulations; collectively with the applicable portions of the Temporary Regulations, the Transferability Guidance) relating to the transfer of certain clean technology industry federal income tax credits pursuant to Section 6418 of the Internal Revenue Code of 1986, as amended (the Code), which was enacted under the Inflation Reduction Act of 2022 (IRA).