New IRS Guidance for PTC and ITC Domestic Content Bonus Credit: Key Issues, Taxpayer Eligibility, New Safe Harbors

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Thursday, August 8, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This CLE/CPE webinar will provide attorneys and tax professionals insight on key components of recent IRS updated guidance regarding the domestic content bonus credit under Sections 45, 48, 45Y, and 48E. The panel will discuss key items under recently issued Notice 2024-41, applicable projects and the domestic content bonus opportunity, the description of domestic content items, certification and recordkeeping requirements, and next steps for taxpayers.
Faculty

Ms. Levin-Nussbaum's practice encompasses a broad spectrum of US federal income tax matters, with a particular emphasis on renewable energy transactions and financing.

Mr. Nickel advises business on a broad range of energy issues related to U.S. federal, state, and local taxes. He has provided counsel on the qualification of transactions for renewable energy tax credits, application of existing tax laws to new technologies, multi-state product launch transactions, and resolution of tax controversies at the federal and state level.

Mr. Kaden has practiced federal income taxation since 2007. He has special expertise in the federal income taxation of flow-through entities, including partnerships, LLCs, and S corporations, and is an industry leader in the structuring and taxation of energy transactions, particularly in the energy transition and decarbonization areas. In his previous role at North America’s largest developer of renewable energy, Mr. Kaden was responsible for the structuring and tax-advantaged financing of over $10 billion in renewable energy and decarbonization projects via tax equity and private equity, and many more through public equity and debt raises. He was also responsible for all tax advice and modeling for the company’s publicly traded yieldco and electricity hedging and trading activities.
Description
The Inflation Reduction Act created a 10 percent tax credit adder to encourage the use of "domestic content" for projects that qualify for the production tax credit (PTC) and investment tax credit (ITC). The domestic content bonus credit is available to projects that qualify for the ITC or PTC under current Sections 48 or 45, or Sections 48E or 45Y beginning in 2025 if all of the steel and iron and the required percentage of manufactured products included in the completed project are produced in the United States.
On May 12, 2023, the IRS published Notice 2023-38, providing the rules for establishing satisfaction of the requirements to qualify for the bonus credit and a safe harbor regarding the classification of certain components. However, on May 16, 2024, the IRS issued further guidance under Notice 2024-41, providing clarity surrounding the domestic content bonus credit.
IRS Notice 2024-41 significantly modifies guidance provided in Notice 2023-38 by adding a new elective safe harbor for taxpayers to qualify for the bonus amount, expanding the applicable project component safe harbor for determining which parts of a clean energy project qualify, and other key items.
Tax professionals assisting developers, manufacturers, and investors must understand these domestic content requirements and the potential challenges involved in satisfying them. This involves a thorough analysis of complex rules, providing evidence that may be difficult to obtain, and consideration of available planning strategies to address related matters concerning expected tax credits, financing, and the overall success of a project.
Listen as our panel discusses recently issued Notice 2024-41, applicable projects and the domestic content bonus opportunity, description of domestic content items, certification and record-keeping requirements, and next steps for taxpayers.
Outline
- Inflation Reduction Act of 2022: 10 percent domestic content bonus credit on renewables
- Impact of 10 percent bonus credit for projects
- Notice 2024-41: key provisions and challenges
- Certification and recordkeeping
- Key issues and pitfalls to avoid for renewable projects
Benefits
The panel will discuss these and other key issues:
- Inflation Reduction Act of 2022 and the 10 percent domestic content bonus credit
- Key items and challenges stemming from IRS Notice 2024-41
- Requirements and processes involved to qualify for the domestic content bonus credit
- Determining classification of the components of the completed project in light of recent guidance
- Safe harbor requirements and pitfalls to avoid
- Navigating the certification and recordkeeping requirements
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Understand the application of the 10 percent domestic content bonus tax credit under the Inflation Reduction Act
- Identify key items and challenges stemming from IRS Notice 2024-41
- Ascertain the requirements and processes involvedin acquiringe the domestic content bonus tax credit
- Recognize which products are considered "domestic content" items for purposes of the bonus tax credit
- Understand the interplay of the 10 percent domestic content bonus and other tax credits
- Ascertain the certification and recordkeeping requirements for the bonus tax credit for projects
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite: Three years plus business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of practical guidance to avoid the most common and costly risk areas in corporate tax compliance, exemptions, deductions, net operating losses, and sales and use tax compliance.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Unlimited access to premium CPE courses.:
- Annual access
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- Best for CPAs and tax professionals
Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
- Annual access
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- Best for legal, accounting, and tax professionals
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