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Internal Revenue Code (IRC) Energy Projects Energy Sector

Holland & Knight LLP

Navigating the Domestic Content Requirements Under Evolving IRS Guidance

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The IRS issued Notice 2025-08 on Jan. 16, 2025, which provides updated guidance regarding the domestic content requirements under Sections 45, 48, 45Y and 48E of the Internal Revenue Code – the investment tax credits and...more

Cadwalader, Wickersham & Taft LLP

Treasury Finalizes Key Energy Tax Credit Guidance Amid a Dry January

Enacted in August 2022, the Inflation Reduction Act (the “IRA”) expanded energy tax credits by increasing credit amounts across the board and broadening eligibility criteria to include new technologies....more

Eversheds Sutherland (US) LLP

Expected flurry of executive actions leaves open questions for the energy tax credits under the IRA at the start of Trump’s second...

On January 20, 2025, Donald J. Trump was inaugurated as the 47th President of the United States. As expected, President Trump took several executive actions in his first hours in office. The discussion below considers the...more

Baker Botts L.L.P.

Inflation Reduction Act Guidance: IRS and Treasury Release Final Regulations on the New Tech-Neutral Clean Energy Tax Credits

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On January 15, 2025, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) published final regulations regarding the new “clean electricity production credit” under Internal Revenue Code...more

King & Spalding

Treasury and IRS Issue Final Regulations Implementing Section 45V Clean Hydrogen Production Tax Credit

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On January 3, 2025, the IRS and Treasury issued long-awaited final regulations (the “45V Final Regulations”) implementing the clean hydrogen production tax credit (the “45V Credit”) under Section 45V of the Internal Revenue...more

Husch Blackwell LLP

Carbon Capture: Tax Impacts of Utilization & Storage

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One promising solution to climate change is Carbon Capture, Utilization and Storage (“CCUS”). CCUS involves capturing carbon oxides, primarily carbon dioxide (CO2), for permanent storage or potential utilization. Interest in...more

Baker Botts L.L.P.

Final Section 45V Clean Hydrogen Production Tax Credit Regulations Issued

Baker Botts L.L.P. on

On January 3, 2025, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) released long-awaited final regulations regarding the clean hydrogen production tax credit under section 45V of the...more

A&O Shearman

Significant updates in Treasury's final energy credit regulations

A&O Shearman on

The U.S. Treasury Department and the Internal Revenue Service (“IRS”) published final regulations on December 4, 2024, defining “energy property” and rules applicable to energy credits (the investment tax credit, or the...more

Baker Donelson

Final Energy Credit Regulations Under Section 48

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Overview - The final regulations, scheduled to be published in final form by the Internal Revenue Service (IRS) and the Department of the Treasury on December 12, 2024, provide comprehensive rules regarding the energy credit...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations on Section 48 Investment Tax Credits

On December 4, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) regarding the investment tax credit (ITC) under Section 48 of the...more

Holland & Knight LLP

Highlights of Final Regulations Under Section 45X Advanced Manufacturing Tax Credit

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The U.S. Department of the Treasury and IRS on Oct. 28, 2024, published final regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (Final Regulations)....more

ASKramer Law

Energy Tax Credits for a New World Part VIII: Monetizing Energy Tax Credits

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What is “monetization”? Monetization is the process by which property is converted into money or something else of value. In the context of the Inflation Reduction Act of 2022 (IRA), certain provisions can allow entities that...more

ASKramer Law

Energy Tax Credits for a New World Part VII: Low-Income Communities Bonus Credits

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What is the Low-Income Communities Bonus Credit? The Low-Income Communities Bonus Credit available through the Inflation Reduction Act of 2022 (IRA) is designed to increase the siting of, and access to renewable energy...more

Sheppard Mullin Richter & Hampton LLP

Solar PV Project Repowering - Best Practices and Insights

In August 2022, the United States (U.S.) Congress passed the Inflation Reduction Act of 2022 (the “IRA”), landmark legislation that modified and extended the longstanding 30% investment tax credit (ITC) for solar photovoltaic...more

Holland & Knight LLP

Eyes on Energy Tax Update: Second Quarter 2024

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Eyes on Energy Tax Update is a regular publication of the Holland & Knight Renewable and Alternative Energy Tax Team that provides highlights of important developments. The Renewable and Alternative Energy Tax Team also...more

Holland & Knight LLP

IRS Releases 2024 Section 45 Production Tax Credit Amounts

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The IRS on July 11, 2024, released 2024 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code. The guidance provides that: Section 45 allows a renewable energy PTC for generating electricity from...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release New Safe Harbor Election for Domestic Content Bonus Credits

On May 16, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2024-41 (the Notice), providing further guidance on domestic content bonus credit amounts applicable under...more

McGuireWoods LLP

IRS Issues New Safe Harbor for 10% Domestic Content Bonus

McGuireWoods LLP on

On May 17, 2024, the IRS released Notice 2024-41, which provides new safe harbors for determining certain energy projects’ qualification for the 10% domestic content bonus under the production tax credit (PTC) and investment...more

Clark Hill PLC

[Webinar] Preparing for Clean Energy Tax Credit Transfer Transactions - May 1st, 12:00 pm - 1:00 pm EDT

Clark Hill PLC on

Project developers in the EV, solar, wind, battery, CCUS, hydrogen, biofuels, and energy efficiency markets have been blessed by the IRS with the ability to transfer tax credits directly to willing buyers. Tax equity...more

Morgan Lewis

IRS Guidance and Impact on the Energy Storage Industry

Morgan Lewis on

The Inflation Reduction Act of 2022 (IRA) enacted a wide range of legislation intended to further a variety of policy goals, including decarbonization, energy and resource security, environmental justice, and good-paying job...more

Holland & Knight LLP

Inflation Reduction Act Direct Pay and Transfer Pre-Filing Registration Is Open for Business

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The IRS launched its Inflation Reduction Act (IRA) Pre-Filing Registration Tool in late 2023 for elective (direct) payments under Section 6417 and tax credit transfers under Section 6418 of the Internal Revenue Code....more

Holland & Knight LLP

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

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The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

A&O Shearman

Takeaways from Treasury's proposed regulations on U.S. tax credits for clean hydrogen production

A&O Shearman on

The U.S. Treasury Department (Treasury) and the Internal Revenue Service (the IRS) issued proposed regulations on December 22, 2023, providing initial guidance on the clean hydrogen tax credit under section 45V (the 45V...more

Morgan Lewis

Treasury and IRS Publish Much-Anticipated Guidance on Clean Hydrogen Tax Credit

Morgan Lewis on

The Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) recently published proposed regulations (Proposed Regulations) setting forth rules applicable to the credit for the production of clean...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Regulations on Section 45X Advanced Manufacturing Credit

On December 15, 2023, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) regarding the advanced manufacturing production...more

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