Tax Credits
IRA to OB3 Transition
IRA ERA
(Through Dec 31, 2024)
TRANSITION PERIOD
(Jan 1 - Jul 4, 2025)
OBBB ERA
(After Jul 4, 2025)
Section 45 PTC (Legacy Renewable)
Section 45Y PTC (Clean Energy)
Construction: Begin by Dec 31, 2024
Construction: Begin by Dec 31, 2032
Sunset: Later of 2032 or emissions targets
Sunset: Later of 2032 or emissions targets
FEOCTaxpayer cannot be SFE/FIE after Dec 31, 2025; Material Assistance prohibited after Dec 31, 2025
Wind/Solar: Begin by July 4, 2026 OR placed in service by Dec 31, 2027; Other Tech: Begin by Dec 31, 2033
Other Tech Sunset: Phaseout starts 2034
Wind/Solar: Begin by July 4, 2026 OR placed in service by Dec 31, 2027; Other Tech: Begin by Dec 31, 2033
Other Tech Sunset: Phaseout starts 2034
Other Tech
- Geothermal power generation
- Hydropower facilities
- Biomass facilities
- Advanced Nuclear facilities
- Any other zero or negative lifecycle greenhouse gas emissions electricity generation technology
Section 48 ITC (Legacy Energy)
Section 48E ITC (Clean Electricity)
Construction: Begin by Dec 31, 2024
Geothermal heat pumps: phaseout 2032-2034
Geothermal heat pumps: phaseout 2032-2034
30% credit for geothermal projects constructed by Dec 31, 2032; Credit reduces to 26% in 2033 and 22% in 2034
Construction: Begin by Dec 31, 2032
Sunset: Later of 2034 or emissions targets
Sunset: Later of 2034 or emissions targets
FEOCTaxpayer cannot be SFE/FIE after Dec 31, 2025; Material Assistance prohibited after Dec 31, 2025; 100% recapture risk
Wind/Solar: Begin by July 4, 2026 OR placed in service by Dec 31, 2027; Other Tech: Begin by Dec 31, 2033
Other Tech Sunset: Phaseout starts 2034
Wind/Solar: Begin by July 4, 2026 OR placed in service by Dec 31, 2027; Other Tech: Begin by Dec 31, 2033
Other Tech Sunset: Phaseout starts 2034
Other Tech
- Geothermal power generation
- Hydropower facilities
- Biomass facilities
- Energy Storage Technology (batteries, pumped hydro, etc.)
- Fuel Cell Property
- Any other zero or negative lifecycle greenhouse gas emissions electricity generation technology
Section 45X PTC (Manufacturing)
Based on: production/sale dates
Components Sunset: Phaseout 2030-2032
Minerals: Permanent
Components Sunset: Phaseout 2030-2032
Minerals: Permanent
Based on: production/sale dates
Components Sunset: Phaseout 2030-2032
Minerals: Permanent
Components Sunset: Phaseout 2030-2032
Minerals: Permanent
FEOCTaxpayer cannot be SFE/FIE after Dec 31, 2025; Material Assistance prohibited after Dec 31, 2025
Based on: production/sale dates
Wind components: Terminated after Dec 31, 2027
Integrated components: Terminated after Dec 31, 2026
Metallurgical coal: Terminated after Dec 31, 2029
Critical minerals: Phaseout 2031-2033
Other eligible components: Sunset 2030-2032 (unchanged)
Based on: production/sale dates
Wind components: Terminated after Dec 31, 2027
Integrated components: Terminated after Dec 31, 2026
Metallurgical coal: Terminated after Dec 31, 2029
Critical minerals: Phaseout 2031-2033
Other eligible components: Sunset 2030-2032 (unchanged)
Section 45V PTC (Clean Hydrogen)
Construction: Begin by Dec 31, 2032
Note: Credit created in IRA but implementation begins Jan 1, 2025
FEOCNone (notably exempt)
Construction: Begin by Dec 31, 2027
Construction: Begin by Dec 31, 2027
Section 45Q Credit (Carbon Capture)
Construction: Begin by Jan 1, 2033
Construction: Begin by Jan 1, 2033
FEOCTaxpayer cannot be SFE/FIE after Dec 31, 2025
Construction: Begin by Jan 1, 2033 (unchanged)
Construction: Begin by Jan 1, 2033 (unchanged)
Section 45U PTC (Nuclear Power)
Applies to: existing facilities
Sunset: Dec 31, 2032
Sunset: Dec 31, 2032
Applies to: existing facilities
Sunset: Dec 31, 2032
Sunset: Dec 31, 2032
FEOCTaxpayer cannot be SFE after Dec 31, 2025; Cannot be FIE 2 years post-enactment (Jul 4, 2027)
Applies to: existing facilities
Sunset: Dec 31, 2032 (unchanged)
Applies to: existing facilities
Sunset: Dec 31, 2032 (unchanged)
Section 45Z PTC (Clean Fuel)
Based on: fuel sale dates
Sunset: Dec 31, 2027
Sunset: Dec 31, 2027
Note: Credit created in IRA but implementation begins Jan 1, 2025
FEOCTaxpayer cannot be SFE after Dec 31, 2025; Cannot be FIE 2 years post-enactment (July 4, 2027)
Based on: fuel sale dates
Sunset: Extended to Dec 31, 2029
Based on: fuel sale dates
Sunset: Extended to Dec 31, 2029
Vehicle Credits (30D, 25E, 45W)
FEOCLimited (EV battery supply chain only)
Based on: Purchase/acquisition
Sunset: Dec 31, 2032
Based on: Purchase/acquisition
Sunset: Dec 31, 2032
FEOCLimited (EV battery supply chain only)
Based on: Purchase/acquisition
Sunset: Dec 31, 2032
Based on: Purchase/acquisition
Sunset: Dec 31, 2032
TERMINATED
FEOCN/A (credits terminated)
30D & 25E & 45W: Terminated Sept 30, 2025
30C (Refueling): Terminated June 30, 2026
FEOCN/A (credits terminated)
30D & 25E & 45W: Terminated Sept 30, 2025
30C (Refueling): Terminated June 30, 2026
Residential Credits (25C, 25D, 45L)
Based on: Installation/acquisition
25C: Through 2032; 25D: Through 2034; 45L: Through 2033
25C: Through 2032; 25D: Through 2034; 45L: Through 2033
Based on: Installation/acquisition
25C: Through 2032; 25D: Through 2034; 45L: Through 2033
25C: Through 2032; 25D: Through 2034; 45L: Through 2033
TERMINATED
FEOCN/A (credits terminated)
25C: Terminated Dec 31, 2025; 25D: Terminated Dec 31, 2025
45L: Terminated June 30, 2026; 179D: Terminated June 30, 2026
FEOCN/A (credits terminated)
25C: Terminated Dec 31, 2025; 25D: Terminated Dec 31, 2025
45L: Terminated June 30, 2026; 179D: Terminated June 30, 2026
- SFE (Specified Foreign Entity): companies and persons from China, North Korea, Russia, and Iran, as well as parties specifically identified on a list of concerning actors, such as foreign terrorist organizations, OFAC-listed entities, Chinese military companies, or Uyghur Forced Labor list entities
- FIE (Foreign Influenced Entity): Entities where SFEs have ≥25% ownership (single) or ≥40% (combined), ≥15% debt ownership, board appointment authority, or "effective control" through payments
- FEOC (Foreign Entity of Concern): Encompasses both SFEs and FIEs as defined above
- Material Assistance: Includes engineering, procurement, construction, operation, maintenance, or financial support from prohibited entities
Quick Look
45Y
Modified
Modified requirements
Wind and solar must be placed in service before Dec. 31, 2027
48E
Modified
Modified requirements
Wind and solar must be placed in service before Dec. 31, 2027
45X
Phased-Out
Multiple phase-outs
Various deadlines by component type
45V
Phased-Out & No FEOC
Eliminated
For projects beginning construction after Dec. 31, 2027
45Q
Price Change
$17/ton base rate
Updated standard starting in 2025
45U
FEOC Only
No change
Status unchanged
45Z
Extended
Extended
Extended through Dec. 31, 2029
EV
Phased-Out
Multiple termination dates
Various EV credits ending between 2025-2026
RES
Phased-Out
Multiple termination dates
Various residential credits ending between 2025-2026