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

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Friday, March 29, 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 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.
Faculty

Ms. Loomis is a tax attorney and CPA with many years of experience in the energy industry. Her in-house experience with a Fortune 500 energy company, understanding of clients’ tax accounting considerations, and face-to-face experience with the IRS make her an invaluable member of the tax practice.

Mr. Mowbray focuses his practice on U.S. federal income tax matters, with an emphasis on international tax and the taxation of financial products. He regularly advises clients on ways to enhance the tax efficiency of commercial transactions and operating structures, including outbound investments by U.S. multinationals, inbound investments by non-U.S. multinationals, the structuring of cross-border financings, internal restructurings and reorganizations, and acquisitions. Mr. Mowbray also regularly advises clients on controversy matters involving the recognition of income, transfer pricing and the international tax provisions of the Tax Cuts and Jobs Act of 2017. In addition, he has significant experience with advising clients on digital asset transactions, offerings and entity and investment structures.
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.
Outline
- Inflation Reduction Act of 2022 and impact on manufacturers
- In depth discussion of the various types of eligible components
- Section 45X MPTC requirements and limitations
- Key provisions of recent IRS guidance
- General rules and definitions
- Sales to unrelated persons
- Eligible components and credit values
- How the proposed regulations treat contract manufacturing arrangements
- Credits for critical minerals
- Direct pay
- 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
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Recognize key tax provisions of the Inflation Reduction Act and the impact on manufacturers
- Understand the requirements and limitations of Section 45X MPTC
- Ascertain key considerations in determining the best circumstances for utilizing Section 45X vs. Section 48C tax credits
- Identify key issues and pitfalls to avoid when claiming the Section 45X MTPC
- 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, utilizing various tax credits, and 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.:
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- Best for CPAs and tax professionals
Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
- Annual access
- Available live and on-demand
- Best for legal, accounting, and tax professionals
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