The Inflation Reduction Act of 2022 (the “IRA”) introduced a wide range of new and enhanced tax credits across clean energy sectors, including renewable energy, clean hydrogen, nuclear power, carbon sequestration and more. On June 14, 2023, the Department of the Treasury and the Internal Revenue Service released further guidance on transferability under the IRA in the form of proposed regulations addressing the requirements and process of electing to transfer tax credits. The market for clean energy tax credits has become substantially more active following the released guidance. The attached memo discusses the guidance and outlines important considerations to keep in mind for prospective tax credit purchasers.