WEBINAR

The Inflation Reduction Act introduced the technology-neutral investment tax credit (ITC) under Internal Revenue Code Section 48E which also included the new concept of a qualified facility. What the new Code Section and Treasury Regulations did not specifically include is how to apply the historically project level prevailing wage and apprenticeship (PWA) compliance requirements to a qualified facility. This is a key tax credit compliance consideration for securing the full 30% ITC credit. 

Because renewable energy projects are planned, financed, and built as a single project, applying PWA requirements at the qualified facility level can create complexity for developers, contractors, investors, tax teams, and advisors. A more practical project-level PWA framework appears to have been the intent of lawmakers which would help support real world implementation and improve compliance consistency. This project level compliance framework would still require reporting PWA data at the qualified facility level to support the required tax return Forms 3468 and 7220. 

Join members from CohnReznick, SunVest Solar, LLC, Standard Solar, and Vinson & Elkins for a discussion on how renewable energy stakeholders are approaching Section 48E PWA compliance, including key considerations for project level PWA compliance, documentation, and allocation methodologies for tax return reporting. 

What we’ll cover: 

• Project-level vs. facility-level compliance considerations 
• How Section 48E guidance may shape PWA strategy 
• IRS reporting alignment, including Form 7220 considerations 
• Practical allocation approaches to support defensible outcomes 
• Ways to reduce compliance complexity and execution risk 

Who should attend: 

• Clean energy developers and sponsors
• Tax, finance, and accounting leaders
• Legal, tax counsel, and advisory professionals 
• Compliance and reporting teams   
• Investors across renewable energy 

SPEAKERS

Jenny Speck

Partner,

Tax

Vinson & Elkins

 Ryan Sterling
Corporate Counsel - Operations
Standard Solar

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