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On September 12, 2024, the Department of the Treasury and the Internal Revenue Service issued long-awaited proposed regulations (the “Proposed Regulations”) on the application of the corporate alternative minimum tax, which imposes a 15% corporate alternative minimum tax on the adjusted financial statement income (“AFSI”) of certain large corporations for tax years beginning after December 31, 2022.
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, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued Proposed Treasury Regulations 110412-23 (the “Proposed Regulations”), providing additional guidance on the “Low-Income Communities Bonus” available under section 48(e) of the Internal Revenue Code of 1986, as amended (the “Code”), for eligible wind, solar, and storage projects.
In what appears to have been an update to previously released guidance, the Department of Treasury (the “Treasury”) and Internal Revenue Service (the “IRS”) posted an unexpected update to Notice 2023-29 (the “Notice”) providing guidance on the energy community bonus credit available for certain production and investment tax credits.
On February 13, 2023, the Department of Treasury, along with the Internal Revenue Service and the Department of Energy, issued Notice 2023-17, establishing a program under section 48(e) of the Internal Revenue Code of 1986, as amended, to allocate the “Low-Income Community Bonus” that is available in connection with the Code section 48 Investment Tax Credit (the “ITC”) among eligible wind, solar, or storage projects.
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 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.