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Energy Sector Renewable Energy Internal Revenue Code (IRC)

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

Holland & Knight LLP

IRS Releases Long-Awaited Section 45Q LCA Procedures

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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

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

Mitchell, Williams, Selig, Gates & Woodyard,...

Transferability of Energy Credits under the Inflation Reduction Act: What do you need to know?

Now that final regulations on the transferability of energy tax credits under the Inflation Reduction Act have been issued by the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS), many investors...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Treasury, Internal Revenue Service Issue Final Regulations for Transfer of Energy Credits

On April 25, 2024, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations regarding the transfer of energy tax credits under the Inflation Reduction Act of 2022 (IRA)....more

McGuireWoods LLP

IRS Issues New Safe Harbor for 10% Domestic Content Bonus

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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

Bradley Arant Boult Cummings LLP

Inflation Reduction Act Domestic Content Bonus Update: IRS Issues Updated Guidance with New Elective Safe Harbor

On May 16, 2024, the IRS released Notice 2024-41 (the “Notice”), modifying its preliminary guidance issued last May in Notice 2023-38 addressing the application of potential future rules that taxpayers must satisfy to qualify...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

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

A&O Shearman

Inflation Reduction Act: New Guidance on Section 45X Manufacturing Tax Credits

A&O Shearman on

On December 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released proposed regulation [REG-107423-23] to provide guidance on the manufacturing tax credit requirements under...more

Skadden, Arps, Slate, Meagher & Flom LLP

Transferability: IRS Guidance Energizes Participation in a New Tax Credit Monetization Strategy

The Inflation Reduction Act (IRA) of 2022 reflected a push by Congress and the Biden administration to address climate change by broadening the applicability of tax credits traditionally available for renewable energy to new...more

Holland & Knight LLP

An In-Depth Look at Section 45X Proposed Regulations

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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

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Long-Awaited Proposed Regulations on Section 48 Investment Tax Credits

On November 17, 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 investment tax credit (ITC) under...more

DarrowEverett LLP

What IRS’s Low-Income Adder Guidance Means For Renewables Projects

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The Inflation Reduction Act of 2022 (the “Act”) breathed new life into the tax scheme for renewable energy projects, creating a new base tax credit with a series of adders that can significantly increase viability of projects...more

Holland & Knight LLP

Eyes on Energy Tax Update: Second Quarter 2023

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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

Bricker Graydon LLP

Ohio General Assembly Modifies Tax Abatements for Renewable Projects

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The primary property tax abatement used by renewable energy projects in Ohio is the Qualified Energy Project (QEP). Originally passed in 2010 (128-SB-232), the QEP program enables qualifying projects to receive an abatement...more

Holland & Knight LLP

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

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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

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Rules Regarding Direct Payment and Transferability of Certain Energy Tax Credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released two notices of proposed rulemaking regarding the direct payment of certain energy tax credits under Section 6417 of...more

Holland & Knight LLP

Treasury Department and IRS Release Direct Pay and Transferability Guidance

Holland & Knight LLP on

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

Perkins Coie

Domestic Content Adder Guidance: Hits and Misses

Perkins Coie on

The U.S. Department of the Treasury (Treasury) issued Notice 2023-38 (the Notice) on May 12, 2023, which contains the first rules concerning the domestic content bonus credits for renewable electricity, renewable natural gas,...more

Morgan Lewis

New Tax Credits and Monetization Opportunities for Energy Storage Have the Chance to Revolutionize the Industry

Morgan Lewis on

The Inflation Reduction Act of 2022 (IRA), which was signed into law on August 16, 2022, enacted a wide range of legislation addressing climate change, healthcare, prescription drug pricing, and tax matters. Specific to...more

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