On April 30, 2024, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) published Final Treasury Regulations (T.D. 9993) (the “Final Regulations”) providing guidance relating to the election under Section 6418 of the Internal Revenue Code of 1986, as amended (the “Code”), to transfer certain tax credits (the “Transfer Election”). The Final Regulations follow previously issued Proposed Treasury Regulations (REG-101610-23) (the “Proposed Regulations”) and Temporary Regulations (T.D. 9975) (the “Temporary Regulations”), each published in June 2023, which provided guidance with respect to the Transfer Election and set forth mandatory information and registration requirements for making Transfer Elections. The Final Regulations, effective on July 1, 2024, serve to finalize the Proposed Regulations and remove the Temporary Regulations. The Final Regulations largely conform to the Proposed and Temporary Regulations, with a few changes and several clarifications. This Deep Dive provides background with respect to the Transfer Election and discusses the key changes and clarifications set forth in the Final Regulations