On July 30, President Trump’s Working Group on Digital Assets released its comprehensive “Strengthening American Leadership in Digital Financial Technology” report (the Report). The 160-plus-page report sets forth a series of recommendations seeking to “ensure crypto becomes a hallmark of the new American Golden Age” while outlining a proposed framework for regulating digital assets. A key section of the Report focuses on the taxation of digital assets and sets forth proposals on the modernization of the tax framework to better align with the realities of the digital asset ecosystem. The proposals address a range of substantive tax issues, including the classification of digital assets for tax purposes, the timing and character of income from mining and staking activities, and the tax treatment of stablecoins, and also recommends updates to taxpayer and third-party reporting requirements.

On Friday, July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (the OBBB), making permanent many of the tax provisions enacted under the 2017 Tax Cuts and Jobs Act and enacting many of the policy objectives of the Trump administration.  The following discussion summarizes at a high level some of the more significant consequences of the OBBB to the wind and solar industry—specifically, to the tech-neutral investment and production tax credits for solar and wind projects under Sections 45Y and 48E (the PTC and ITC, respectively) of the Internal Revenue Code (the Code).  The IRS and Department of the Treasury are also expected to issue additional guidance and regulations to interpret the OBBB.  Among other expected areas of additional guidance, on July 7, 2025, the Trump White House released Executive Order “Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources” (the BOC EO), announcing its specific intention to cause Treasury to issue new guidance relating to the Beginning of Construction rules applicable under the ITC and PTC.On Friday, July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (the OBBB), making permanent many of the tax provisions enacted under the 2017 Tax Cuts and Jobs Act and enacting many of the policy objectives of the Trump administration.  The following discussion summarizes at a high level some of the more significant consequences of the OBBB to the wind and solar industry—specifically, to the tech-neutral investment and production tax credits for solar and wind projects under Sections 45Y and 48E (the PTC and ITC, respectively) of the Internal Revenue Code (the Code).  The IRS and Department of the Treasury are also expected to issue additional guidance and regulations to interpret the OBBB.  Among other expected areas of additional guidance, on July 7, 2025, the Trump White House released Executive Order “Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources” (the BOC EO), announcing its specific intention to cause Treasury to issue new guidance relating to the Beginning of Construction rules applicable under the ITC and PTC.