Notice 2024-13: Request for comments on product identification number requirement for energy efficiency home improvement
The credit is allowed for qualifying property placed in service on or after January 1, 2023, and before January 1, 2033.
The credit is allowed for qualifying property
The IRS today released Notice 2024-13 [PDF 138 KB] requesting comments on implementation of the product identification number (PIN) requirement with respect to the energy efficient home improvement credit under section 25C, as amended by Pub. L. No. 117-169 (commonly called the “Inflation Reduction Act of 2022” (IRA)).
Background
As explained in the related IRS release—IR-2023-253 (December 29, 2023)—beginning January 1, 2023, the energy efficient home improvement credit allows for a credit, subject to certain limitations and caps, equal to 30% of the total amount paid by the taxpayer for certain qualified expenditures, including:
- Qualified energy efficiency improvements installed during the year
- Residential energy property expenditures during the year
- Home energy audits during the year
The credit is allowed for qualifying property placed in service on or after January 1, 2023, and before January 1, 2033.
Beginning January 1, 2025, taxpayers claiming the credit must also satisfy the PIN requirement for certain categories of products. Under this requirement, an item will only qualify for the energy efficient home improvement credit if the item is produced by a qualified manufacturer, and if the taxpayer includes the qualified PIN of the item on their tax return.
The IRS previously requested comments on various questions arising from the IRA’s energy efficiency provisions, including sections 25C, 25D, 45L and 179D, in Notice 2022-48 (read TaxNewsFlash). The IRS specifically requested comments on certain issues relating to the PIN requirement under 25C, and it describes the comments it received in today’s Notice 2024-13, along with its ultimate conclusion that appropriate implementation of the PIN requirement makes it necessary to develop a system that assigns PINs to each unique item of specified property.
Request for comments
Notice 2024-13 requests comments on a number of general and specific questions that will inform the development of a system to assign unique PINs to each item of specified property and also outlines a PIN assignment system that the IRS is considering.
Comments are due by February 27, 2024, although consideration will be given to comments received after that date if the consideration will not delay the issuance of guidance.
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