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

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

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

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

The One, Big, Beautiful Bill Update

Beautiful Bill Update

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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