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On December 4, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations [TD 10015] (the “Final Regulations”) for the energy credit available under section 48 (the “ITC”) of the Internal Revenue Code of 1986, as amended (the “Code”).

On November 7, Vinson & Elkins hosted an Energy Transition and Inflation Reduction Act (IRA) Conference in its New York office.

Much has been written about the benefits of tax credit transfers following the passage of the Inflation Reduction Act (IRA), but questions remain as to how to actually effectuate a transfer.

On August 30, 2024, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) providing additional guidance to taxpayers on the “Low-Income Communities Bonus” (“LICB”) available under section 48E(h) of the Internal Revenue Code of 1986, as amended.

In this article, published by PFI and written in conjunction with etasca, Alan Alexander, Lauren Davies, Andrew Nealon and Louis Molloy discuss the challenges and potential solutions for scaling Power-to-X (P2X) technologies to meet global net-zero targets. P2X involves converting renewable energy into low-carbon products like hydrogen, e-methanol, and sustainable aviation fuel (SAF).

On May 29, 2024, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations (REG-119283-23) (the “proposed regulations”) regarding the clean electricity production tax credit and the clean electricity investment tax credit provided by the Inflation Reduction Act of 2022 (the “IRA”)¹ and available under new sections 45Y and 48E, respectively, of the Internal Revenue Code of 1986, as amended (the “Code”).

By 2050, the cost of producing low-carbon hydrogen is expected to be five times higher in the most expensive regions than the least expensive regions, according to the Hydrogen Council.

Vinson & Elkins was delighted to host its First Annual Energy Transition and Inflation Reduction Act Conference.

On April 25, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for certain tax credits by eligible taxpayers available under section 6418 of the Internal Revenue Code of 1986, as amended (the “Code”).

In this article, published by Global Hydrogen Review, Lauren Davies, Andrew Nealon, Alistair Wishart and Garrett Finch examine some of the key challenges associated with using a ‘traditional’ project finance model in the development of low-carbon hydrogen projects and will also consider some potential solutions.

On March 5, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Final Direct Pay Regulations”) regarding the direct pay election for certain tax credits available under section 6417 of the Internal Revenue Code of 1986, as amended (the “Code”).

Just in time for the Christmas holiday, early this morning the U.S. Internal Revenue Service (“IRS”) and Department of Treasury (“Treasury”) released highly anticipated regulations governing the Section 45V Clean Hydrogen Tax Credit.