On June 14, 2023, the Treasury Department and the Internal Revenue Service (IRS) released long-awaited guidance (the Credit Transfer Guidance) regarding the transfer of energy transition tax credits under Section 6418, which was enacted under the Inflation Reduction Act of 2022 (the IRA). The Credit Transfer Guidance is in the form of proposed regulations (the Proposed Regulations), temporary regulations (the Temporary Regulations), and frequently asked questions posted on the IRS website.
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