Energy Tax Benefits and Inflation Reduction Act

The Inflation Reduction Act ("Act") extended, expanded, and modified existing clean energy tax credits and allowed for additional credit enhancements for eligible taxpayers. Since the Act was signed on August 16, 2022, there has been a flurry of questions and guidance by the IRS to assist taxpayers. This course provides an overview of the various energy tax benefits that are available for taxpayers under the Act, including traditional tax equity structures that remain vital to understanding how taxpayers receive benefits. This course will also discuss some of the bonuses that are available and the proposed regulations which provided long-awaited guidance on the elective payment and transferability regimes, along with open issues and other considerations. Finally, this course will also discuss the mechanics of determining the beginning of construction date and how it impacts the availability of energy tax credits.

Learning Objectives:

1. Break down energy tax credit and deprecation deduction concepts relevant to the structuring of tax equity and similar transactional structures
2. Identify concepts and considerations embodied in traditional tax equity and similar structures as they existed prior to the Inflation Reduction Act
3. Analyze how the modeling of benefits is a critical element of such structuring
4. Review key changes to the energy tax credit provisions by the IRA
5. Analyze the impact of the IRA changes on tax equity and similar transactional structuring, including the impact of the transferability of certain credits and direct payment of credit benefits to exempt entities