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New IRS Guidance for Section 48C Qualifying Advanced Energy Project Credit

Notice 2023-18, Qualified Investments, Eligible Property, Placement in Service, Allocation Procedures, Energy Communities

Note: CPE credit is not offered on this program

Recording of a 90-minute premium CLE video webinar with Q&A

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Conducted on Wednesday, June 21, 2023

Recorded event now available

or call 1-800-926-7926

This CLE webinar will provide renewable energy counsel, developers, and investors guidance on key provisions of recent IRS guidance on the Section 48C Qualifying Advanced Energy Project Credit. The panel will discuss categories of projects considered to be "qualifying advanced energy projects" under the Internal Revenue Code and Notice 2023-18, qualified events, eligible property, placement in service, allocation procedures, and other key issues.

Description

The Inflation Reduction Act of 2022 (IRA) modified the credit for "qualifying advanced energy projects" under Section 48C of the Internal Revenue Code. Counsel, developers, and investors must understand the requirements of Section 45C in order to maximize tax benefits and take advantage of the tax credits.

New Section 48C allows a taxpayer to claim the tax credit for any taxable year in an amount equal to a base rate of six percent of the taxpayer's "qualified investment" for that taxable year with respect to any "qualifying advanced energy project" owned by the taxpayer. This base rate increases to 30 percent for taxpayers satisfying certain prevailing wage and apprenticeship requirements with respect to the project.

IRS Notice 2023-18 provides initial procedures for applications and allocations of the Section 48C credit program providing significant insights such as (1) the categories of projects that are considered to be a "qualifying advanced energy project," (2) qualified investments, eligible property, and placement in service, and (3) allocation procedures, as well as other key items that must be considered.

Listen as our panel discusses "qualifying advanced energy projects" under the Internal Revenue Code and Notice 2023-18, qualified investments, eligible property, placement in service, allocation procedures, and related challenges.

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Outline

  1. Overview of Section 48C
  2. Impact of the Inflation Reduction Act
  3. IRS Notice 2023-18
  4. Allocation procedures and challenges
  5. Best practices for counsel, developers, and investors

Benefits

The panel will discuss these and other key issues:

  • What are the requirements for acquiring the Section 48C tax credit?
  • What is the impact of the IRA?
  • What are the key issues and challenges in light of IRS Notice 2023-18?
  • What projects meet the requirements of a "qualifying advanced energy project"?
  • What issues are presented relating to qualified investments, eligible property, and placement in service?
  • What are the required allocations and necessary procedures?

Faculty

Barakat, Shariff
Shariff N. Barakat
Partner
Akin Gump Strauss Hauer & Feld

Mr. Barakat represents clients involved in the acquisition, development and financing of power generation and...  |  Read More

LaBerge, Kami
Kami LaBerge
Attorney
Paul Hastings

Ms. LaBerge provides advice on a wide range of domestic and international transactional tax matters. She has experience...  |  Read More

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