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On October 24, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Final 45X Regulations”) regarding the Advanced Manufacturing Production Tax Credit (the “AMP Credit”) under section 45X of the Internal Revenue Code of 1986, as amended (the “Code”).
As Vinson & Elkins prepares to host its “Energy Transition and IRA Conference” in New York on November 7, 2024 (just two days after the upcoming presidential election), we ask ourselves, where have we been and where might we be going with the Inflation Reduction Act of 2022 (the IRA)?
Much has been written about the benefits of tax credit transfers following the passage of the Inflation Reduction Act (IRA), but questions remain as to how to actually effectuate a transfer.
On September 18, 2024, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) (1) issued proposed regulations (the “Proposed Regulations”) providing guidance to taxpayers on the Alternative Fuel Vehicle Refueling Property Credit available under section 30C of the Internal Revenue Code of 1986, as amended (“30C Credit”) and (2) released Notice 2024-64 (the “Notice”)1 to correct certain technical issues related to mapping tools used to identify eligible census tracts for the 30C Credit.2
On August 30, 2024, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) providing additional guidance to taxpayers on the “Low-Income Communities Bonus” (“LICB”) available under section 48E(h) of the Internal Revenue Code of 1986, as amended.
On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage and apprenticeship requirements (the “PWA Requirements”) impacting many of the clean energy tax credits introduced or expanded by the Inflation Reduction Act of 2022 (the “IRA”).
On May 31, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service continued to churn out Inflation Reduction Act of 2022 (“IRA”)1 guidance by releasing Notice 2024-49 (the “Notice”) regarding the clean fuel production tax credit (the “45Z Credit”)2 available under new section 45Z of the Internal Revenue Code of 1986, as amended.
On May 29, 2024, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations (REG-119283-23) (the “proposed regulations”) regarding the clean electricity production tax credit and the clean electricity investment tax credit provided by the Inflation Reduction Act of 2022 (the “IRA”)1 and available under new sections 45Y and 48E, respectively, of the Internal Revenue Code of 1986, as amended (the “Code”).
The volatility of energy prices following recent geopolitical challenges has brought a renewed focus on domestic energy security.
The emergence of generative artificial intelligence (AI) is driving a surge in demand for power-hungry data centre capacity in Europe.
On May 16, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued Notice 2024-41 (the “Notice”), which provides supplemental guidance on the domestic content bonus credit (the “Domestic Content Bonus”). While stakeholders may have been hoping for a more fulsome set of proposed regulations, the Notice still provides meaningful updates and clarifications to the previously issued guidance under Notice 2023-38 (the “Prior DC Notice”).1