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Maximizing Elective Payment: How the Attestation Safe Harbor Protects Direct‑Pay Value through 2026

Matt McKinney March 6, 2026

Maximizing Elective Payment: How the Attestation Safe Harbor Protects Direct Pay Value through 2026 The Inflation Reduction Act (IRA) introduced elective payment (also known as direct pay) under IRC §6417, allowing certain tax exempt and governmental entities (“Applicable Entities”) to receive refundable payments in lieu of energy tax credits under Sections 45, 45Y, 48, and 48E. However, Congress also imposed statutory phaseouts that reduce or eliminate direct pay benefits for projects not meeting Domestic Content requirements. IRS Notice 2024-9 and

Maximizing Elective Payment: How the Attestation Safe Harbor Protects Direct‑Pay Value through 2026

March 6, 2026 No Comments

Interim Guidance on Special Depreciation for Qualified Production Property (QPP)

IRS Notice 2026-16 Summary Interim Guidance on Special Depreciation for Qualified Production Property (QPP) The IRS recently issued Notice 2026-16, providing interim guidance on the 100% special depreciation allowance for Qualified Production Property (QPP) under Internal Revenue Code §168(n). This provision was enacted as part of the One, Big, Beautiful

March 4, 2026 No Comments

Interim Guidance on Special Depreciation for Qualified Production Property (QPP)

IRS Notice 2026-16 Summary Interim Guidance on Special Depreciation for Qualified Production Property (QPP) The IRS recently issued Notice 2026-16,

Matt McKinney March 4, 2026

one big beautiful bill act

Bonus Depreciation and the Component Election

Bonus Depreciation and the Component Election: A New Planning Opportunity for Construction Projects Recent tax legislation has reshaped bonus depreciation

Matt McKinney February 17, 2026

one big beautiful bill

IRS Releases Rev. Proc. 2025-28: New Guidance on R&D Deductions Under OBBBA

IRS Releases Rev. Proc. 2025-28: New Guidance on R&D Deductions Under OBBBA On August 28, 2025, the IRS issued Rev.

Deb Roth, CPA, Matt McKinney August 29, 2025

R&D

Tax Cuts and Jobs Act Impacts R&D Tax Credit

Tax Cuts and Jobs Act Impacts R&D Tax Credit Given the recent passage of the Tax Cuts and Jobs Act,

Source Advisors February 18, 2018

House of Reps Unveiled Three Proposed Tax Bills

House Bills Spur Discussion of Business Tax Extenders On Friday, June 9, 2023, the House of Representatives unveiled three proposed tax bills. We view these bills as an opening offer, unlikely to pass in their present form, but they will inform later Congressional debate. In this summary, we will focus

Matt McKinney June 12, 2023

Revised IRS Procedural Guidance Released

R&E Amortization Updates On December 12th, 2022, the Service released an advance copy of Rev. Proc. 2023-8, which provides procedural guidance for taxpayers to adopt accounting methods for specified research or experimental expenditures under Code section 174 as modified by the Tax Cuts & Jobs Act, Pub. Law No. 115-97. https://www.irs.gov/pub/irs-drop/rp-23-08.pdf

Matt McKinney December 13, 2022

COST SEGREGATION

Proposed Section 1031 Regulations

Proposed Section 1031 Regulations On June 12th, 2020, the Treasury published REG-117589-18 in the Federal Register. These proposed reliance regulations provide guidance on the definition of “real property” under Code § 1031. The definition in the proposed regulations would permit many assets identified as shorter-life property in a cost segregation study to

Greg Bryant June 27, 2020

Rev. Proc. 2020-22 Changes to the Section 163(J) Interest Limitation

Rev. Proc. 2020-22 Changes to the Section 163(J) Interest Limitation On April 10th, 2020, the Internal Revenue Service posted Rev. Proc. 2020-22 to its website. This new revenue procedure provides guidance allowing taxpayers to make or revoke certain elections under Code section 163(j) and also provides guidance on the implementation

Greg Bryant April 27, 2020

§179D

§179D

IRS Announcement 2024-24: Updated Reference Standard 90.1 for § 179D

IRS Announcement 2024-24: Updated Reference Standard 90.1 for § 179D Announcement 2024-24 refers to the upcoming updates that will align

Imran Syed May 20, 2024

cost segregation operating loss paperwork

§179D | §45L

Inflation Reduction Act Tax Savings For Real Estate

Inflation Reduction Act Tax Savings for Real Estate On Tuesday, August 16, 2022, the Senate passed the Amendment of H.R. 5376,

Imran Syed July 21, 2023

45L | 179D

Treasury Releases Green Book

Energy Efficient Commercial Buildings Deduction On Friday, May 28th, 2021, the Treasury Department released the Green Book, also known as the

Imran Syed June 4, 2021

§179D

Energy Efficient Commercial Buildings Deduction

Energy Efficient Commercial Buildings Deduction On December 27, 2020, a $1.4 trillion omnibus spending bill with tax extenders was signed

Imran Syed December 30, 2020

woman using phone with money signs floating above

R&D | §179D

New Bill Outlines Covid Relief and Economic Stimulus Provisions

New Bill Outlines Covid Relief and Economic Stimulus Provisions Congress passed the Appropriations bill, which included the latest Covid relief

Deb Roth, CPA December 12, 2020

New Bill Outlines Covid Relief and Economic Stimulus Provisions

New Bill Outlines Covid Relief and Economic Stimulus Provisions Congress passed the Appropriations bill, which included the latest Covid relief and economic stimulus provisions. The bill fulfilled a long-awaited promise by Congress to clarify the treatment of the Payroll Protection Plan’s forgiveness. Since the passage of the PPP, one of

Deb Roth, CPA December 12, 2020

§45L

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45L

Notice 2023-65: New Guidance on Section 45L Energy Efficient Home Credit

Notice 2023-65: New Guidance on §45L Energy Efficient Home Credit Section 45L Energy Efficient Home Credit was extended and amended

Imran Syed October 28, 2023

§179D | §45L

Inflation Reduction Act Tax Savings For Real Estate

Inflation Reduction Act Tax Savings for Real Estate On Tuesday, August 16, 2022, the Senate passed the Amendment of H.R. 5376,

Imran Syed July 21, 2023

45L | 179D

Treasury Releases Green Book

Energy Efficient Commercial Buildings Deduction On Friday, May 28th, 2021, the Treasury Department released the Green Book, also known as the

Imran Syed June 4, 2021

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Tax News

Explore Recent Tax News

Maximizing Elective Payment: How the Attestation Safe Harbor Protects Direct‑Pay Value through 2026

Maximizing Elective Payment: How the Attestation Safe Harbor Protects Direct‑Pay Value through 2026

Interim Guidance on Special Depreciation for Qualified Production Property (QPP)

Interim Guidance on Special Depreciation for Qualified Production Property (QPP)

Bonus Depreciation and the Component Election

IRS Releases Rev. Proc. 2025-28: New Guidance on R&D Deductions Under OBBBA

R&D

Tax Cuts and Jobs Act Impacts R&D Tax Credit

House of Reps Unveiled Three Proposed Tax Bills

Revised IRS Procedural Guidance Released

COST SEGREGATION

Proposed Section 1031 Regulations

Rev. Proc. 2020-22 Changes to the Section 163(J) Interest Limitation

§179D

IRS Announcement 2024-24: Updated Reference Standard 90.1 for § 179D

Inflation Reduction Act Tax Savings For Real Estate

Treasury Releases Green Book

Energy Efficient Commercial Buildings Deduction

New Bill Outlines Covid Relief and Economic Stimulus Provisions

New Bill Outlines Covid Relief and Economic Stimulus Provisions

§45L

Notice 2023-65: New Guidance on Section 45L Energy Efficient Home Credit

Inflation Reduction Act Tax Savings For Real Estate

Treasury Releases Green Book

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