Tax Equity News

Tax Credits Eligible for Direct Pay or Transferability Under the Inflation Reduction Act

Posted by Gabrielle Jacques

August 29, 2022

Posted in Blog article Renewable energy


Tax Credit

Section 6417 Refundability

(Direct Pay)

Section 6418 Transferability

(Third Party Sale) [1]

§25E Previously-Owned Clean Vehicles No; but, see special rule for advanced payments on transfer under Transferability. No; but, taxpayer who purchases a pre-owned clean vehicle can elect, on or before the purchase date, to transfer the credit to the dealer who sold the vehicle in exchange for cash, or a partial payment or a down payment on the vehicle in an amount equal to the credit otherwise available to the buyer.
§30C Alternative Fuel Vehicle Refueling Property Credit Yes; but limited to tax-exempt entities. Yes
§30D Clean Vehicle Credit No; but, see special rule for advanced payments on transfer under Transferability. No; but, taxpayer who purchases a new clean vehicle can elect, on or before the purchase date, to transfer the credit to the dealer who sold the vehicle in exchange for cash, or a partial payment or a down payment on the vehicle in an amount equal to the credit otherwise available to the buyer.
§45 Renewable Electricity Production Tax Credit Yes; but limited to tax-exempt entities. Yes
§45Q Carbon Oxide Sequestration Credit Yes; not limited to tax-exempt and state governmental entities during first five years of the credit period. Yes
§45U Zero-Emission Nuclear Power Production Credit Yes; but limited to tax-exempt entities. Yes
§45V Clean Hydrogen Production Credit Yes; not limited to tax-exempt and state governmental entities during first five years of the credit period Yes
§45W Qualified Commercial Vehicles for a Tax-Exempt Entity Yes; but limited to tax-exempt entities. No
§45X Advanced Manufacturing Production Credit Yes; not limited to tax-exempt and state governmental entities during for any consecutive five-year period elected by taxpayer within the credit period. Yes
§45Y Electricity Production Credit Yes; but limited to tax-exempt entities. Yes
§45Z Clean Fuel Production Credit Yes; but limited to tax-exempt entities. Yes
§48 Energy Investment Tax Credit Yes; but limited to tax-exempt entities. Yes
§48C Qualifying Advanced Energy Project Credit Yes; but limited to tax-exempt entities. Yes
§48E Clean Electricity Investment Credit Yes; but limited to tax-exempt entities. Yes

[1] Tax-exempt entities are excluded from using transferability.

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