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Navigating the Domestic Content Requirements Under Evolving IRS Guidance

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

Questions and Answers: Initial Section 45Z Clean Fuel PTC Guidance

The U.S. Department of the Treasury and IRS on Jan. 10, 2025, released initial guidance regarding the production tax credit (PTC) for clean fuels under Section 45Z of the Internal Revenue Code, as enacted by the Inflation...more

Key Highlights of the Section 761 Final Regulations and Impact on Section 6417 Direct Payments

Under Section 6417 of the Code, as enacted by the Inflation Reduction Act (IRA), certain taxpayers that fall within the statutory definition of "applicable entities" are allowed to elect to receive a direct payment (i.e.,...more

Key Highlights of the Section 48 ITC Final Regulations

The U.S. Department of the Treasury and IRS on Dec. 12, 2024, issued Final Regulations regarding the investment tax credit (ITC) for Section 48 of the Internal Revenue Code, including the ITC for energy generation, energy...more

IRS Releases Long-Awaited Section 45Q LCA Procedures

The IRS on July 24, 2024, released Notice 2024-60, which provides Section 45Q guidance for utilization of carbon dioxide and other carbon oxides. The Notice addresses the information that must be included in the required life...more

Eyes on Energy Tax Update: Second Quarter 2024

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

Treasury Department, IRS Issue Additional Section 45V Clean Hydrogen PTC Guidance

The U.S. Department of the Treasury Department and IRS on April 10, 2024, issued a supplemental notice of proposed rulemaking (NPRM) under the Internal Revenue Code's Section 45V clean hydrogen production tax credit (PTC)....more

Treasury Department, IRS Correct Section 48 Proposed Regulations on Qualified Biogas Property

The U.S. Department of the Treasury and IRS on Feb. 16, 2024, released a correction to Internal Revenue Code Section 48 Proposed Regulations relating to the new investment tax credit (ITC) for biogas. The correction provides...more

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

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

An In-Depth Look at Section 45X Proposed Regulations

The U.S. Department of the Treasury and IRS on Dec. 14, 2023, released Proposed Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. (See Holland& Knight's previous...more

Breaking Down the Section 48 Investment Tax Credit Proposed Regulations

The U.S. Department of the Treasury and IRS on Nov. 17, 2023, released long-awaited proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code. Section...more

Section 48 Proposed Regulations Detail Treatment of Qualified Biogas Property

The U.S. Department of the Treasury on Nov. 17, 2023, issued proposed regulations (Proposed Regulations) regarding the investment tax credit (ITC) under Section 48 of the Internal Revenue Code (Code) that, following passage...more

Eyes on Energy Tax Update: Second Quarter 2023

The second quarter of 2023 saw continued developments as a result of the enactment of the Inflation Reduction Act of 2022 (IRA), court activity and announcements from federal agencies. Below, we summarize the updates you need...more

Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more

IRS Releases 2023 Section 45 Production Tax Credit Amounts

The IRS on June 21, 2023, released 2023 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code. That guidance provides that: Section 45 allows a renewable energy PTC for generating electricity from...more

IRS Issues Updated Energy Community Bonus Guidance

The IRS on June 15, 2023, updated its energy community bonus guidance by issuing Notice 2023-45 and Notice 2023-47. The IRS also recently issued energy community bonus guidance in Notice 2023-29. (For a summary of Notice...more

Treasury Department and IRS Release Direct Pay and Transferability Guidance

The U.S. Department of the Treasury and IRS on June 14, 2023, released two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax credits under Section 6417 of the Internal Revenue Code (Elective Payment...more

Break Out Your Calculator: IRS Releases Domestic Content Bonus Credit Guidance

Following the release of energy community bonus credit and low-income community bonus credit guidance, the U.S. Department of the Treasury and IRS recently provided taxpayers with the domestic content bonus credit guidance....more

Eyes on Energy Tax Update: First Quarter 2023

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. ...more

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