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On June 14, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed and temporary regulations regarding the transfer elections for certain tax credits available under section 6418 of the Internal Revenue Code of 1986, as amended (the “Code”).
On February 13, 2023, the Department of Treasury (the “Treasury”), along with the Internal Revenue Service (the “Service”) and the Department of Energy (the “DOE”), issued Notice 2023-18 (the “Notice”), establishing a program under section 48C(e)(1) of the Internal Revenue Code of 1986, as amended (the “Code”), to allocate $10 billion of tax credits for qualifying investments in eligible advanced energy projects (the “Advanced Energy Project Credit”).
On August 12, 2022 – a little over two weeks after the legislation was announced and five days after it passed the Senate – the House passed the historic Inflation Reduction Act of 2022 (the “Act”).
On July 27, 2022, only a few hours after the Senate approved a bipartisan semiconductor and technology package, Senator Manchin made a stunning and well-timed reversal of his prior position and confirmed his support for various climate and energy programs. Senate Democrats (led by Senators Manchin and Schumer) quickly made legislative text available and submitted it to the Senate Parliamentarian for review.