Notice 2024-49: Registration requirements for section 45Z clean transportation fuel production credit
Taxpayer must have signed registration letter dated on or before January 1, 2025, to be eligible to claim the credit
Taxpayer must have signed registration letter dated on or before January 1, 2025
The IRS today released Notice 2024-49 providing guidance on the registration requirements for the clean transportation fuel production credit under section 45Z, as established by H.R. 5376 (commonly called the “Inflation Reduction Act of 2022” (IRA)).
As explained in the related IRS release—IR-2024-153 (May 31, 2024)—section 45Z allow a credit for the production of clean transportation fuels beginning on January 1, 2025. For purposes of the credit, transportation fuel is divided into two broad categories of fuel: sustainable aviation fuel (SAF) and non-SAF transportation fuel. The credit is equal to the product of the applicable amount per gallon (or gallon equivalent) for any transportation fuel that is produced by the taxpayer at a qualified facility during the tax year and the emissions factor for such fuel. One of the requirements to qualify for the credit is that the fuel producer must be registered at the time the fuel is produced.
Notice 2024-49 provides that a taxpayer must have a signed registration letter from the IRS dated on or before January 1, 2025, for the taxpayer to be eligible to claim the section 45Z credit for production starting January 1, 2025. Thus, taxpayers are advised to apply for registration as soon as possible to give the IRS sufficient time to process registration applications.
The notice provides that the IRS intends to process completed applications for registration received by July 15, 2024, such that an eligible taxpayer can receive its letter of registration by January 1, 2025. The IRS intends to quickly process applications received after July 15, 2024, but cautions that a taxpayer that applies for registration after that date is less likely to receive its registration by January 1, 2025. In no event can the IRS guarantee that any application for registration will be processed by a certain date.
The notice states that Treasury and the IRS intend to issue additional guidance on other aspects of the section 45Z credit at a later date.
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