Executive Summary The One, Big, Beautiful Bill Act, which is commonly known as OBBBA and was enacted on July 4, 2025, introduced significant restrictions on clean energy tax credits under Internal Revenue Code Sections 45X, 45Y, and 48E to limit involvement from Prohibited Foreign Entities, or PFEs. IRS Notice 2026-15 provides interim guidance on these … Read more
The Investment Tax Credit (ITC) has become one of the most valuable incentives driving energy efficiency and renewable energy projects under the Inflation Reduction Act, but many design engineers aren’t aware of how their work directly affects a project’s eligibility and credit value. We walk through which technologies qualify, how prevailing wage and apprenticeship compliance … Read more
For years, the Investment Tax Credit was treated as something handled after a project was designed, built, and placed in service. That approach no longer works. Under the Inflation Reduction Act and clarified further under OBBBA, geothermal and energy storage projects sit at the center of ITC opportunity. They also sit at the center of … Read more
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
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
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
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
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
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
UPDATES On May 12, 2025, the House Ways and Means Committee released its budget reconciliation bill titled “The One, Big, Beautiful Bill.” This bill proposes several broad changes to the Internal Revenue Code, including the rollback or phase-out of several clean energy incentives introduced under the Inflation Reduction Act (IRA). Key energy-related provisions include: Section … Read more
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