Navigating Prohibited Foreign Entity Restrictions in Clean Energy Tax Credits: An Analysis of IRS Notice 2026-15

Navigating Prohibited Foreign Entity Restrictions in Clean Energy Tax Credits: An Analysis of IRS Notice 2026-15

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

Project Labor Agreements in the Context of Section 48 and 48E Investment Tax Credits: Enhancing Compliance with Prevailing Wage and Apprenticeship Requirements

Executive Summary The Inflation Reduction Act (IRA) of 2022 has significantly expanded tax incentives for clean energy projects through enhancements to the Investment Tax Credit (ITC) under Sections 48 and 48E of the Internal Revenue Code. A key feature of these incentives is the opportunity for taxpayers to claim a fivefold increase in the credit … Read more

2025 NREL Geothermal Market Report: Key Insights for Owners, Developers, and Engineers

As we kick off 2026, the clean energy landscape is heating up—literally. The National Renewable Energy Laboratory (NREL) just dropped their 2025 U.S. Geothermal Market Report, and it’s packed with data confirming what we’ve been seeing on the ground: geothermal energy has one of the strongest long-term runways in renewables. But success hinges on smart … Read more

Provisions in the Section 48 and 48E Investment Tax Credits: Navigating Domestic Content Requirements for Elective Pay

Executive Summary The Inflation Reduction Act (IRA) of 2022 introduced transformative incentives for clean energy investments, including the Investment Tax Credit (ITC) under Sections 48 and 48E of the Internal Revenue Code. A key feature is the elective payment option, commonly known as “direct pay,” which allows certain entities—such as tax-exempt organizations, governments, and tribal … Read more

Webinar: What Design Engineers Need to Know About the Investment Tax Credit (ITC)

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

Why ITC Success for Geothermal and Storage Projects Is Won or Lost Before Construction Starts

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

Year-End Planning for Energy Tax Incentives: Deadlines That Matter Going Into 2026

As we close out the year, several energy tax incentive deadlines are approaching that deserve immediate attention. We are already seeing projects miss opportunities simply because planning started too late. The goal of this note is to highlight the timelines that matter most for ITC, 179D, and housing-related incentives, and to encourage early coordination so … Read more

Webinar: What Design Engineers Need to Know About the Investment Tax Credit (ITC)

January 22, 2026 – 2 PM EST REGISTER 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. Join Walker Blue for … Read more

Webinar: Cutting Operating Costs with Federal Energy Tax Incentives

Cutting Operating Costs with Federal Energy Tax Incentives: How to get started This webinar explains how Elective Pay under the Inflation Reduction Act—maintained through the One Big Beautiful Bill Act (OBBBA), gives government and nonprofit organizations a time-limited opportunity to convert federal energy tax credits into cash payments. Learn how these funds can directly support … Read more

Understanding the Apprenticeship Requirements for Energy Tax Incentives

The Inflation Reduction Act (IRA) introduced Prevailing Wage and Apprenticeship (PWA) requirements across major federal energy tax incentives, including the Investment Tax Credit (ITC), Production Tax Credit (PTC), and §179D deduction.These standards are now a key part of qualifying for the full credit value—typically multiplying the base incentive by five for projects that meet both … Read more

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