Establishing the Beginning of Construction for Small-Scale Solar Projects: Leveraging the 5% Safe Harbor Under IRS Notice 2025-42

Executive Summary The enactment of the One Big Beautiful Bill Act (OBBBA) on July 4, 2025, has introduced stringent deadlines for qualifying for the Clean Electricity Investment Tax Credit (ITC) under Internal Revenue Code (IRC) Section 48E, particularly for solar energy projects. To secure the full 30% credit, project owners must ensure that construction begins … Read more

Aggregation of Multiple Solar Energy Properties Under the Investment Tax Credit: Implications for Common Owners

Executive Summary The Investment Tax Credit (ITC) under Section 48 of the Internal Revenue Code provides significant incentives for solar energy development, including a base credit and bonus adders for meeting criteria such as prevailing wage and apprenticeship (PWA) requirements, domestic content, and location in energy communities. A key consideration for developers and owners is … Read more

IRS Issues FAQs on OBBBA Energy Incentives: What It Means for 179D and 48E

By David Diaz, CSO, Walker Blue, LLC On August 21, 2025, the IRS released Fact Sheet FS-2025-05, providing answers to frequently asked questions (FAQs) about the impact of the One Big Beautiful Bill Act (OBBBA) on several energy credits and deductions. While the fact sheet is not binding legal authority, it does provide important clarity … Read more

Navigating Apprenticeship Requirements Under the Inflation Reduction Act: Compliance, Penalties, and Remedies

Executive Summary The Inflation Reduction Act (IRA) of 2022 introduced prevailing wage and apprenticeship (PWA) requirements to qualify for enhanced tax credits and deductions in clean energy and other qualifying projects. These requirements aim to promote skilled labor development while ensuring fair compensation. This white paper focuses on the three key apprenticeship requirements—Apprenticeship Labor Hour … Read more

Understanding IRS Notice 2025-42: Navigating the New Beginning of Construction Rules for Clean Electricity Credits in Wind and Solar Projects

By Josh Howes, CEO Executive Summary The clean energy landscape is evolving rapidly, with significant legislative and regulatory changes aimed at promoting sustainable development while ensuring fiscal responsibility. IRS Notice 2025-42, issued in response to the One Big Beautiful Bill Act (OBBBA) and Executive Order 14315, introduces stringent guidelines for determining when construction begins on … Read more

The New FEOC Rules for Section 48E: Implications for Clean Energy Investments Under the One Big Beautiful Bill Act

By: Josh Howes, CEO Executive Summary The Clean Electricity Investment Tax Credit under Section 48E of the Internal Revenue Code (IRC) represents a pivotal incentive for advancing zero-emission electricity generation and energy storage technologies in the United States. However, the recently enacted One Big Beautiful Bill Act (OBBBA), signed into law on July 7, 2025, … Read more

OBBBA Fixes Domestic Content Discrepancy in IRA

Walker-Blue-Domestic-Content

In the One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, the domestic content bonus under Section 48E (the clean electricity investment tax credit, or ITC) provides an additional 10 percentage points to the base credit rate (or 2 percentage points if prevailing wage and apprenticeship requirements are not met) for … Read more

Exhibiting: EEI Fall 2025 National Key Accounts Workshop, Sept 28 – Oct 1

Walker Blue will be exhibiting at the Fall 2025 National Key Accounts Workshop, September 28th – October 1st, in Birmingham, Alabama. Connect with the team to discuss how we can help maximize energy efficiency tax incentives for your renewable energy projects and building energy conservation measures. About the Event: EEI’s semi-annual National Key Accounts Workshop … Read more

Speaking: Geothermal Rising Conference, Oct 26 – 29

Walker Blue will be speaking at the 2025 Geothermal Rising Conference, October 26 – 29, in Reno, Nevada. Connect with the team to discuss how we can help maximize energy tax incentives for your geothermal projects. About the Event: The GRC is the geothermal industry’s flagship annual conference, reflecting the global nature of the geothermal … Read more

Energy Tax Incentive News: May 22, 2025

Company Update: Blue Energy Group and Walker Reid Strategies will be merging. Read the official announcement. UPDATES This week, the House passed its version of the “One Big Beautiful Bill,” and it includes major cuts to clean energy tax incentives. Most notably, the bill proposes to eliminate Section 48E, a key credit for clean electricity … Read more

Contact Walker Blue Today