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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

California Legislature Passes AB 85 and Suspends the Usage of New-Operating Losses

California Legislature Passes AB 85 and Suspends the Usage of New-Operating Losses California’s Legislature recently passed AB 85, a budget bill that, in part, suspends the usage of net-operating losses and restricts the utilization of business tax credits, including the research credit. The Governor signed the bill into law on

Source Advisors July 15, 2020

VA Extended Application Deadline to September 1, 2020

VA Extended Application Deadline to September 1, 2020 In a recent legislative update, the Virginia General Assembly modified the two state research credit programs resulting in changes that have both current and future implications. The Research and Development Expenses Tax Credit has been extended through 2024 from the current sunset

Source Advisors June 18, 2020

COST SEGREGATION

Final and Proposed 100 Percent Bonus Depreciation Regs

Final and Proposed 100 Percent Bonus Depreciation Regs On Friday, September 13, 2019, the Internal Revenue Service released advance copies of final 100 percent bonus depreciation regulations and new, proposed 100 percent bonus depreciation regulations. These regulations have not yet been published in the Federal Register. Until they are, they

Greg Bryant September 19, 2019

Revenue Procedure 2019-33

Revenue Procedure 2019-33 On July 31, 2019, the IRS released Rev. Proc. 2019-33. This revenue procedure allows taxpayers to make or revoke certain elections for bonus depreciation under the Tax Cuts and Jobs Act of 2017 (TCJA) for the 2016 and 2017 tax years. The late and revoked elections create many

Greg Bryant August 5, 2019

§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

§45L

stack of newspapers with news of source advisors

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

California Legislature Passes AB 85 and Suspends the Usage of New-Operating Losses

VA Extended Application Deadline to September 1, 2020

COST SEGREGATION

Final and Proposed 100 Percent Bonus Depreciation Regs

Revenue Procedure 2019-33

§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

§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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