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On February 4, 2026, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published proposed regulations addressing the clean fuel production tax credit (“45Z Credit”) under section 45Z of the...more
Under Section 45Z of the Internal Revenue Code, a production tax credit (PTC) is available for each gallon or gasoline gallon equivalent of transportation fuel produced after December 31, 2024, and sold before January 1,...more
On January 14, 2026, Senators Pete Ricketts (R-NE) and Chris Coons (D-DE) introduced the Renewable Chemicals Act (S. 3632). According to Ricketts’s January 14, 2026, press release, the bipartisan legislation “would provide a...more
With electricity demand rising across the United States, nuclear power is receiving renewed attention from energy developers, investors, and financiers – both for existing facilities and new projects....more
On October 29, 2025, Democratic members of the House Ways and Means Committee introduced H.R. 5862, the American Energy Independence and Affordability Act (the Bill). The legislation, introduced by Rep. Mike Thompson...more
The Inflation Reduction Act of 2022 created the ability to transfer production tax credits (“PTC”) to an “eligible taxpayer” pursuant to Section 6418 of the Internal Revenue Code (“IRC”). However, exactly when an eligible...more
On Oct. 1, 2025, Gov. Gavin Newsom signed into effect California S.B. 302, which excludes tax credit monetization transactions from the California income tax for taxable years beginning Jan. 1, 2026, and before Jan. 1, 2031....more
On 4 July 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBB), representing a sweeping reset of the United States (U.S.) energy policy. The act drastically pares back the energy transition tax credits...more
Enacted in August 2022, the Inflation Reduction Act (the “IRA”) expanded energy tax credits by increasing credit amounts, broadening eligibility beyond wind and solar, and allowing credits to be developed and sold....more
On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was enacted. Several provisions of the OBBBA will impact renewable energy projects and the tax credits generated by such projects. Such provisions include the...more
The enactment of the One Big Beautiful Bill Act (“OBBBA”) on July 4, 2025 introduced major legal and regulatory changes across various sectors. ...more
In a decision that could make it challenging for wind and solar projects to qualify for the federal Investment Tax Credit (ITC) and Production Tax Credit (PTC), the Internal Revenue Service (IRS) released Notice 2025-42 on...more
On August 15, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2025-42 (Guidance), updating the rules on when construction is considered to have “begun” for purposes of...more
The IRS on Aug. 15, 2025, released Notice 2025-42, which provides guidance on how taxpayers can establish the "beginning of construction" (BOC) of a wind or solar facility for purposes of determining whether such facility is...more
With an effective date of September 2, 2025, New Beginning of Construction guidance will be prospective and not apply to projects that satisfied beginning of construction under old IRS guidance before September 2, 2025. ...more
The One Big Beautiful Bill Act, enacted on July 4, 2025, imposed new restrictions on the availability of the Investment Tax Credit (ITC) and Production Tax Credit (PTC) for wind and solar projects under Code Sections 45Y and...more
On 15 August 2025 the Internal Revenue Service (IRS) released Notice 2025-42 (the Notice), which restricts the methods that developers of wind and solar projects can use to determine whether they have begun construction for...more
In response to Executive Order 14315 (July 7, 2025) (the “July 7 EO”), the IRS released Notice 2025-42 on August 15, 2025. Notice 2025-42 provides rules on how to begin construction for purposes of the effective dates of the...more
On August 15, 2025, the US Department of the Treasury and the Internal Revenue Service (the “IRS”) issued Notice 2025-42 (the “August 2025 Notice”), providing critical guidance on the determination of when construction begins...more
Energy transition is going through what can be described as growing pains. Here to stay, but the reality of what it is going to take to diversify energy resources will take decades. And I stress the word “diversify” as...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
Wind and solar projects seeking to begin construction before July 4, 2026, must meet stricter qualification criteria for some tax incentives....more
On Aug. 15, the U.S. Treasury Department and the Internal Revenue Service (IRS) released IRS Notice 2025-42, narrowing the rules for what qualifies as “beginning of construction” (BOC) under the One Big Beautiful Bill Act...more
The Internal Revenue Service ("IRS") has issued Notice 2025-42 to implement the One Big Beautiful Bill Act ("OBBBA") mandate to phase out the clean electricity production tax credit (§ 45Y) and investment tax credit (§ 48E)...more