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IRS Announces Key Milestones in Implementation of Key Provisions for Clean Energy Tax Credits

On March 19, 2024, the government released interesting statistics related to transferability and project registration.

Here are Atheva’s key takeaways from the release:

  • Of those who have registered (which covers transferability and direct pay), 98% are choosing transferability.
  • 500 entities have registered over 45,500 facilities or projects. This means each entity that is registered is listing over 90 projects, on average.
  • Over 80% of the projects are section ITCs, over 15% are PTCs. This means that these credits combined account for over 95% of the credits being registered. This is consistent with the proportion of credits that we have seen listed with Atheva.
  • The only other credit listed in the release with specific data is the Advanced Manufacturing Credit under Section 45X which seems to account for about 0.1% of projects.
  • The release noted that those that request elective pay (under Code Section 6417) can anticipate payment within 45 days of the due date of their annual return. However, the release warned that in some cases payment may take more time.
  • While the share of requests for transferability do not appear to be a large part of the total, they include registration numbers related to other credits and cited the following.
    • Commercial clean vehicles (45W)
    • Alternative fuel vehicle refueling property (aka EV charging stations) (30C)
    • Carbon oxide sequestration (45Q)
    • Advanced manufacturing facility investment (48D)

      It’s important to note that while the credit registrations outside of section 45 and 48 may be small in number, the projects and credits associated with them to tend to be large. On the other hand, while there are certainly large solar ITC projects, there are many smaller ones as well.
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