On April 29, 2024, the Internal Revenue Service (IRS) released Notice 2024-36, announcing the 2024 allocation (Round 2) of Section 48C qualifying advanced energy project credits totaling approximately $6 billion, with more than $2 billion allocated to energy communities census tracts. The notice also updates and modifies definitions and examples as well as providing information regarding the application process for the allocation of credits. Prior notices established the § 48C(e) program to allocate $10 billion of § 48C credits for qualified investments in eligible qualifying advanced energy projects and provided guidance for the first allocation round of the § 48C(e) program (Round 1).
To be considered for an allocation of § 48C credits in Round 2, taxpayers must first submit concept papers to the IRS through the Qualified Advanced Energy Project Credit Program Applicant Portal (48C Portal) maintained by the Department of Energy (DOE). Following submission of a concept paper, the DOE will provide a letter encouraging or discouraging the taxpayer’s submission of a joint application for DOE recommendation and for IRS § 48C(e) certification. DOE begins the acceptance period for a taxpayer’s § 48C(e) application on the date of the letter of encouragement or discouragement.
To be considered for the § 48C(e) program, a taxpayer’s § 48C(e) application must be submitted no later than 50 calendar days after DOE begins the acceptance period for the taxpayer’s § 48C(e) application. The 48C Portal will open to accept concept paper submissions no later than Tuesday, May 28, 2024. Taxpayers must submit concept papers prior to 5:00 p.m. Eastern Time, within 30 calendar days after the 48C Portal opens. The IRS will make all Round 2 allocation decisions no later than January 15, 2025.
Ryan will issue another alert when the portal is open. Our green credit leader, Ian Boccaccio, advises applicants to begin the process of preparing their concept papers as soon as possible, so they can readily submit their information on the portal as soon as it opens. As time is of the essence, please contact our Ryan tax professionals for assistance with this application process.
TECHNICAL INFORMATION CONTACTS:
Ian Boccaccio
Principal
Ryan
469.399.4545
ian.boccaccio@ryan.com
Nicholaus List
Director
Ryan
917.472.9472
nicholaus.list@ryan.com
Scott Stogsdill
Director
Ryan
469.399.4496
scott.stogsdill@ryan.com
The material presented in this communication is intended to provide general information only and should solely be seen as broad guidance and not directed to the particular facts or circumstances of any individual who may read this publication. No liability is accepted for acts or omissions taken in reliance upon the content of this piece. Before taking (or not taking) any action, readers should seek professional advice specific to their situation from Ryan, LLC or other tax professionals. For additional information about this topic, please contact us at info@ryan.com.
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- Ian Boccaccio