Tax News Update    Email this document    Print this document  

April 25, 2024

IRS releases final rules on transfer of certain energy credits

Treasury and the IRS have released final regulations (TD 9993) on the transfer of certain energy credits under IRC Section 6418, added by the Inflation Reduction Act, which adopt the proposed regulations with some modifications (see Tax Alert 2023-1103). The final regulations describe special rules related to excessive credit transfers and recapture events, including which taxpayer is responsible in such events. The final regulations also clarify the mandatory pre-filing registration process, which must be completed prior to making a transfer election, and provide specific rules for partnerships and S corporations. A Tax Alert is forthcoming.

* * * * * * * * * *
Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor