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Internal Revenue Service Energy Projects Energy Sector

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
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

ASKramer Law

Energy Tax Credits for a New World Part VI: Energy Community Bonus Credits

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What is the purpose of the Energy Community Bonus Credit? The Inflation Reduction Act (IRA) introduced the Energy Community Bonus Credit to encourage renewable energy project developers to locate their facilities and energy...more

ASKramer Law

Energy Tax Credits For A New World Part V: Domestic Content Bonus Credits

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What is the purpose of the Domestic Content Bonus Credit? The Inflation Reduction Act (IRA) introduced the Domestic Content Bonus Credit to provide an additional credit amount to taxpayers that meet its requirements. The...more

ASKramer Law

Energy Tax Credits For A New World Part IV: Prevailing Wage and Apprenticeship Bonus Credits

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Why did Congress provide bonus credits to a facility or a project that pays its workers “prevailing wages” and hires apprentices? Congress viewed the Inflation Reduction Act (IRA) as a way to not only move the United States...more

ASKramer Law

Energy Tax Credits For A New World Part III: Overview of Bonus Credits

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Why did the Inflation Reduction Act (IRA) reduce the base amounts of the energy tax credits? The IRA reduced base credit amounts from their pre-IRA levels to encourage energy projects to meet Congressional policy objectives....more

ASKramer Law

Energy Tax Credits for a New World Part II: Production Tax Credits and Investment Tax Credits: The Old and the New

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What is a Production Tax Credit (PTC)? A Production Tax Credit (PTC) is a per kilowatt-hour (kWh) tax credit for electricity generated by solar and other qualifying clean technologies for the first 10 years of a system’s...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

Vinson & Elkins LLP

Energy Makers Find Limited Answers in Bonus Tax Credit Guidance

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The domestic content bonus is one of the Inflation Reduction Act’s most powerful tax incentives, but so far is proving to be one of the most difficult to earn. The Treasury Department and IRS released Notice...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

Claiming Tech-Neutral Clean Electricity Production and Investment Tax Credits Under the Inflation Reduction Act

On May 29, 2024, the U.S. Department of the Treasury and the Internal Revenue Service released long anticipated Proposed Regulations regarding clean electricity production tax credits and clean electricity investment tax...more

Faegre Drinker Biddle & Reath LLP

IRS Announces Final Regulations Implementing Prevailing Wage and Apprenticeship Requirements for Clean Energy Projects Under the...

On June 18, 2024, the U.S. Treasury Department and the Internal Revenue Service (IRS) published final regulations implementing the prevailing wage and apprenticeship requirements for clean energy tax credits for construction...more

Holland & Knight LLP

The Technology-Neutral Sections 45Y PTC and 48E ITC Are Coming

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The U.S. Department of the Treasury and IRS on May 29, 2024, issued proposed regulations under the new Internal Revenue Code (Code) Section 45Y Clean Electricity Production Tax Credit (PTC) and Section 48E Clean Electricity...more

Mintz - Energy & Sustainability Viewpoints

Energy & Sustainability Washington Update — July 2024

Final Rules for Prevailing Wage & Registered Apprenticeships at Clean Energy Projects - The Department of the Treasury and Internal Revenue Service (IRS) recently announced final rules implementing the prevailing wage and...more

Locke Lord LLP

Locke Lord Deep Dive: Treasury Issues Final Regulations Providing Guidance on Transfer of Certain Credits Under the Inflation...

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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...more

Katten Muchin Rosenman LLP

Transferability of Renewable Energy Tax Credits: Still Gathering Steam

The Inflation Reduction Act of 2022 provides for the transferability of certain renewable energy tax credits, including the investment tax credit (ITC). Although transferability deal volume has certainly increased in the last...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

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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

Holland & Knight LLP

IRS Releases Additional Domestic Content Bonus Credit Guidance

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The IRS on May 16, 2024, released Notice 2024-41, which modifies the existing domestic content safe harbor in Notice 2023-38. Importantly, Notice 2024-41...more

Stoel Rives LLP

Treasury Provides New Safe Harbor for Domestic Content Bonus Credit

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The U.S. Department of the Treasury (Treasury) today released Notice 2024-41, Domestic Content Bonus Credit Amounts under the Inflation Reduction Act of 2022: Expansion of Applicable Projects for Safe Harbor in Notice 2023-38...more

Wilson Sonsini Goodrich & Rosati

DOE and IRS Set to Open Second and Potentially Final Round of Section 48C Qualifying Advanced Energy Project Credit Applications

On April 29, 2024, pursuant to Notice 2024-36, the Department of Energy (DOE) and Internal Revenue Service (IRS) announced that they plan to open the second, and potentially final, round of Section 48C(e) Qualifying Advanced...more

Foley Hoag LLP

IRS Kicks Off 2024 Allocation Round of Qualifying Advanced Energy Project Credit Program

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The Treasury Department and the IRS issued Notice 2024-36 to announce that the second allocation round of the qualifying advanced energy project credit program under Section 48C(e) will commence no later than Tuesday, May 28,...more

Cadwalader, Wickersham & Taft LLP

Tax Insurance May Boost the Market for Energy Tax Credits

The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits.  In our last update, available here, we discussed the latest developments on the “direct pay” rules, the clean...more

Holland & Knight LLP

Treasury Department and IRS Release Final Regulations on the Transfer of IRA Tax Credits

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As provided in the Inflation Reduction Act (IRA), eligible taxpayers may make a yearly election to transfer all (or any portion) of an eligible credit to an unrelated taxpayer under Section 6418 of the Internal Revenue Code,...more

Clark Hill PLC

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

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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

Locke Lord LLP

Latest Energy Communities Guidance Buoys Offshore Wind, but Navigation Hazards ‎Remain

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On March 22, 2024, the IRS issued additional guidance (Notice 2024-30) on the energy communities provision of the Inflation Reduction Act. This latest guidance is narrowly focused on two topics: (1) expanding the “hook” by...more

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