On July 25, 2025, the Internal Revenue Service (IRS or Service) released an Interim Guidance Memorandum dated July 23, 2025 (the IGM) that i) eliminates the Acknowledgement of Facts (AOF) Information Document Requests (IDR) from Large Business & International Division (LB&I) examinations, ii) provides updates on the changes to the Fast Track Settlements (FTS) pilot program, and iii) clarifies the applicability of Accelerated Issue Resolution (AIR) to Large Corporate Compliance (LCC) cases.

Recent legislative proposals—the CLARITY Bill and the GENIUS Act—are designed to bring more clarity to how digital assets are regulated in the United States. The Clarity Bill was passed by the House of Representatives on July 17, 2025, and is now being reviewed by the Senate.

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.