The U.S. Inflation Reduction Act of 2022 not only introduced a range of new and enhanced clean energy-related tax credits, but also created two new ways for taxpayers to monetize these credits—through “direct pay” and “transferability.” On June 14, 2023, the IRS and Treasury Department released a series of proposed regulations addressing the requirements for making a “direct pay” election (to receive refundable payments in lieu of tax credits) and a “transfer” election (to sell the tax credits). The attached memo contains the key takeaways and outlines the requirements for making these elections.
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