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New IRS Guidance on Advanced Manufacturing Production Tax Credit Under the Inflation Reduction Act

General Rules and Definitions, Sales to Unrelated Persons, Impact on Contract Manufacturers, Eligible Components and Related Credit Values, Section 6417 Direct Pay

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

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Conducted on Friday, March 29, 2024

Recorded event now available

or call 1-800-926-7926

This CLE/CPE webinar will provide tax professionals an in-depth analysis of key components of Section 45X tax credits, recent IRS guidance, and key considerations for manufacturers and contract manufacturers. The panel will discuss the 45X advanced manufacturing production credit and recently issued proposed regulations. The panel will also discuss strategies to monetize Section 45X credits.

Description

Manufacturers are eligible for tax credits aimed at supporting manufacturing under IRC Section 45X. Recently, the IRS issued proposed regulations for claiming the Section 45X Advanced Manufacturing Production Tax Credit for producing specific components within the United States. Tax professionals must understand key provisions of the recent guidance, the interplay between 45X MPTC with other credits, and key considerations when determining which tax credit to utilize for manufacturers in light of the recent guidance.

The Inflation Reduction Act of 2022 established 45X MPTC and the "direct pay" option for tax credits under certain circumstances, the tax credit transfer regime, and other key items. The 45X MPTC provides tax credits for each eligible component domestically produced. However, projects cannot claim both the 45X MPTC and 48C credit, making the determination of which should be used a critical component to financing a project.

Listen as our panel discusses eligibility under Section 45X, recent IRS guidance and requirements, and other key items in determining the use of the Section 45X tax credit in light of recent IRS guidance.

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Outline

  1. Inflation Reduction Act of 2022 and impact on manufacturers
    1. In depth discussion of the various types of eligible components
  2. Section 45X MPTC requirements and limitations
  3. Key provisions of recent IRS guidance
    1. General rules and definitions
    2. Sales to unrelated persons
    3. Eligible components and credit values
    4. How the proposed regulations treat contract manufacturing arrangements
    5. Credits for critical minerals
    6. Direct pay
  4. 45X vs. 48C; determining which is best under certain circumstances

Benefits

The panel will discuss these and other key issues:

  • Recent IRS guidance and key considerations and challenges for the Section 45X tax credit
  • Areas of focus in determining the use of 45X MPTC vs. 48C ITC
  • Navigating the application process
  • Best practices for manufacturers

Faculty

Loomis, Anne
Anne C. Loomis
Partner
Troutman Pepper

Ms. Loomis is a tax attorney and CPA with many years of experience in the energy industry. Her in-house experience with...  |  Read More

Mowbray, Nicholas
Nicholas C. Mowbray
Counsel
BakerHostetler

Mr. Mowbray focuses his practice on U.S. federal income tax matters, with an emphasis on international tax and the...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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