KPMG report: Analysis and observations of direct pay and transferable credit proposed regulations

Summary of the operative rules, observations and practical implications

Summary of the operative rules, observations and practical implications

Article Posted date 27 June 2023

The U.S. Treasury Department and IRS on June 14, 2023, released proposed regulations on transferability and direct pay of certain energy-related federal income tax credits, as well as proposed and temporary regulations on related procedural aspects. These proposed procedural regulations apply to section 48D, as well as sections 6417 and 6418.

The proposed regulations are generally applicable to tax years ending on or after the date of publication of final rules. However, taxpayers are permitted to rely on the proposed regulations for tax years beginning after December 31, 2022, provided they apply the proposed regulations in their entirety and in a consistent manner. The temporary regulations apply to tax years ending on or after their publication in the Federal Register on June 21, 2023.

Read a June 2023 report [PDF 529 KB] that provides a summary of the operative rules, as well as observations and practical implications.

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