ITC – Walker Blue

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

September 16, 2025September 15, 2025 by Julie Chesna

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

September 9, 2025September 5, 2025 by Julie Chesna

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

August 28, 2025August 25, 2025 by Julie Chesna

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

August 21, 2025 by Julie Chesna

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

OBBBA Fixes Domestic Content Discrepancy in IRA

August 18, 2025July 18, 2025 by Julie Chesna

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

2025 Tax Law Changes: What Developers, ESCOs, and Project Teams Should Know Now

August 14, 2025July 10, 2025 by Elspeth Curtis

UPDATE The 2025 tax law, known as the “One Big Beautiful Bill,” resets the outlook for tax planning across energy, real estate, and construction. Many credits from the Inflation Reduction Act are being phased out sooner than expected. Others now carry more complexity due to sourcing rules, ownership restrictions, and long-term compliance requirements. For ESCOs, … Read more

Navigating Energy Tax Incentives: 179D, 45L, and ITC in a Changing Political Landscape

August 14, 2025January 15, 2025 by Elspeth Curtis

Over the past year, the Inflation Reduction Act (IRA) has fundamentally reshaped the incentives landscape for energy-efficient buildings and clean energy initiatives. At Walker Reid, we’ve helped building owners, architects, developers, and other stakeholders maximize their tax benefits and navigate new legislative updates—particularly surrounding the 179D deduction, 45L credit, and Investment Tax Credit (ITC). With … Read more

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

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