2025›Rev. Proc. 2024-19 provides the process under section
Part V—Clean Electricity Investment Credit Under Section 48E
2025 Inst 3468 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
Section A—Qualified Clean Electricity Facilities The clean electricity investment credit is the applicable percentage of the qualified investment with respect to any qualified facility during the tax year.
Note: This credit is available for property placed in service after 2024.
Qualified investment. The qualified investment with respect to any qualified facility is the sum of the following.
Instructions for Form 3468 (2025) 15
The basis of any qualified property placed in service by the taxpayer during the tax year which is part of the qualified facility, and
The amount of any expenditures that are paid or incurred by the taxpayer for qualified interconnection property in connection with a qualified facility that has a maximum net output of not greater than 5 MW ac and placed in service during the tax year, and properly chargeable to the capital account of the taxpayer.
Qualified property. Qualified property means property that is:
Tangible personal property or other tangible property (not including a building or its structural components), but only if it’s used as an integral part of the qualified facility;
Depreciation or amortization is allowable; and
The construction, reconstruction, or erection is completed by the taxpayer or is acquired by the taxpayer if the original use of the property starts with the taxpayer.
Qualified facility. A qualified facility means a facility that is used for the generation of electricity and is placed in service after 2024, and the anticipated greenhouse emissions rate (under Regulations section 1.48E-5) is not greater than zero.
A qualified facility will also include either a new unit or an addition of capacity placed in service after 2024, if the facility described above (without regard to being placed in service after 2024), was placed in service before 2025, but only to the extent of the increased amount of electricity produced at the facility by reason of such new unit or addition of capacity.
Caution: You cannot claim the clean electricity investment credit for a facility for which a credit determined under section 45, 45J, 45Q, 45U, 45Y, 48, or 48A is allowed under section 38 for the tax year or any prior tax year.
Caution: For tax years starting after July 4, 2025, no credit will be allowed for property described in section 25D(d)(1) or (4) if the taxpayer rents or leases such property to a third party during the tax year.
Qualified interconnection property. Qualified interconnection property is, with respect to a qualified facility that isn’t a microgrid controller, any tangible property that:
Is part of an addition, modification, or upgrade to a transmission or distribution system that is required at or beyond the point at which the qualified facility interconnects to such transmission or distribution system in order to accommodate such interconnection;
Is either constructed, reconstructed, or erected by the taxpayer, or the cost with respect to the construction, reconstruction, or erection of such property is paid or incurred by the taxpayer; and
The original use, pursuant to an interconnection agreement, starts with a utility.
Material assistance from prohibited foreign entities. If the construction, reconstruction, or erection of a qualified facility or qualified interconnection property, described earlier, includes any material assistance from a prohibited foreign entity (as defined in section 7701(a) (52)) and construction, reconstruction, or erection begins after 2025, no credit will be allowed.
CO2e per KWh. The term "CO2e per KWh” means, with respect to any greenhouse gas, the equivalent carbon dioxide (as determined based on global warming potential) per kilowatt hour of electricity produced.
Greenhouse gas. Greenhouse gas means carbon dioxide, hydrofluorocarbons, methane, nitrous oxide, perfluorocarbons, and sulfur hexafluoride. The Administrator of Public Health and Welfare may include any other anthropogenically emitted gas that is determined by the Administrator of Public Health and Welfare, after notice and comment, to contribute to global warming.
Greenhouse gas emissions rate. Greenhouse gas emissions rate is the amount of greenhouse gases emitted into the atmosphere by a facility in the production of electricity, expressed as grams of CO2e per KWh.
Coordination with rehabilitation credit. The qualified investment for any qualified facility cannot include the portion of the basis of any property that is attributable to qualified rehabilitation expenditures (as defined in section 47(c)(2)) for any tax year.
Certain progress expenditure rules made applicable. Rules similar to the rules of section 46(c)(4) and 46(d) (as in effect on the day before the date of the enactment of P.L. 101-158) apply for purposes of the clean electricity investment credit.
Recapture of credit. For purposes of section 50, if the Secretary determines that the greenhouse gas emissions rate for a qualified facility is greater than 10 grams of CO2e per KWh, any property for which a credit was allowed under this section will cease to be an investment credit property in the tax year in which the determination is made.
Prohibited foreign entity restrictions. In general, for tax years beginning after July 4, 2025, no credit will be allowed for any tax year if the taxpayer is a specified foreign entity (as defined in section 7701(a)(51)(B)) or a foreign-influenced entity (as defined in section 7701(a) (51)(D) without regard to section 7701(a)(51)(D)(i)(ll)). If the taxpayer is determined to be a foreign-influenced entity during any tax year under section 7701(a)(51)(D)(i) (ll), and such determination relates to a qualified facility, no credit will be allowed for such a tax year.
Line 1b
Enter your applicable percentage. See Increased Credit Amount Statement, earlier, for more information.
Qualified fuel cell property. Qualified fuel cell property (defined under section 48(c)(1), without regard to subparagraph (E)), is a qualified facility if the qualified fuel cell property is used for the generation of electricity, and
16 Instructions for Form 3468 (2025)
construction begins after 2026. Enter 30% on line 1b for the applicable percentage.
Caution: If you’re taking a credit for qualified fuel cell property under section 48(c)(1), no other increases or adjustments are allowed. Skip lines 1d through 1n and go to line 2.
Line 1d
Enter your applicable domestic content bonus credit percentage. See Domestic Content Certification Statement , earlier, for more information.
If the facility did not meet the requirements for the domestic content bonus credit, leave line 1d blank, skip line 1e, and go to line 1f.
Line 1f
Enter your applicable energy community bonus credit percentage. See Energy community bonus credit rate , earlier, for more information.
If the facility was not placed in service within an energy community, leave line 1f blank, skip line 1g, and go to line 1h.
Line 1h
Enter your applicable low-income communities bonus credit percentage. See Filers Completing Part V , earlier, for more information.
However, you don’t qualify for the low-income communities bonus credit if either of the following apply.
You checked the box in Part I, line 11g; or
Part I, line 12a(ii), 12b, or 12c(ii), is 5 MW ac or more (in relation to Part I, lines 11a, 11b, 11c, or 11d).
In the case where either 1 or 2 above apply, enter -0- on lines 1h and 1n, and go to line 2.
Section B—Qualified Energy Storage Technology The clean electricity investment credit is the applicable percentage of the qualified investment with respect to any energy storage technology during the tax year.
Note: This credit is available for property placed in service after 2024.
Qualified investment. The qualified investment with respect to energy storage technology for any tax year is the basis of any energy storage technology placed in service by the taxpayer during the tax year.
Energy storage technology. Energy storage technology is:
- Property (other than property primarily used in the transportation of goods or individuals and not for the production of electricity) that receives, stores, and delivers energy for conversion to electricity (or, in the case of hydrogen, that stores energy), and has a
nameplate capacity of not less than 5 kilowatt hours, and
- Thermal energy storage property.
Modifications of certain property. In the case of any energy storage technology property described above, the modified property will be treated as energy storage technology property (except for the treatment of the basis of the existing property prior to the modification), if either of the following applies.
The property is placed in service before August 16, 2022, has a nameplate capacity of less than 5 kilowatt hours, and is modified in a manner where the property has a nameplate capacity of at least 5 kilowatt hours; or
The property is modified in a manner that modifications increase the nameplate capacity by at least 5 kilowatt hours.
Thermal energy storage property. Thermal energy storage property is property comprising a system that:
Is directly connected to a heating, ventilation, or air conditioning system;
Removes heat from, or adds heat to, a storage medium for subsequent use; and
Provides energy for the heating or cooling of the interior of a residential or commercial building.
Thermal energy storage property doesn’t include:
A swimming pool,
Combined heat and power system property,
A building or its structural components, or
Property that transforms other forms of energy into heat in the first instance. See Regulations section 1.48E-2(g)(6)(ii).
Material assistance from prohibited foreign enti ties. If the construction of energy storage technology, described earlier, includes any material assistance from a prohibited foreign entity (as defined in section 7701(a) (52)) and construction begins after 2025, no credit will be allowed.
Prohibited foreign entity restrictions. In general, for tax years beginning after July 4, 2025, no credit will be allowed for any tax year if the taxpayer is a specified foreign entity (as defined in section 7701(a)(51)(B)) or a foreign-influenced entity (as defined in section 7701(a) (51)(D) without regard to section 7701(a)(51)(D)(i)(ll)). If the taxpayer is determined to be a foreign-influenced entity during any tax year under section 7701(a)(51)(D)(i) (ll), and such determination relates to an energy storage technology, no credit will be allowed for such a tax year.
Certain progress expenditure rules made applicable. Rules similar to the rules of section 46(c)(4) and 46(d) (as in effect on the day before the date of the enactment of P.L. 101-158) apply for purposes of the clean electricity investment credit.
Caution: You cannot claim the clean electricity investment credit for a facility for which a credit determined under section 45, 45J, 45Q, 45U, 45Y, 48, or 48A is allowed under section 38 for the tax year or any prior tax year.
Instructions for Form 3468 (2025) 17
Line 3b
Enter your applicable percentage. See Increased Credit Amount Statement , earlier, for more information.
Line 3d
Enter your applicable domestic content bonus credit percentage. See Domestic Content Certification Statement, earlier, for more information.
If the energy storage technology did not meet the requirements for the domestic content bonus credit, leave line 3d blank, skip line 3e, and go to line 3f.
Line 3f
Enter your applicable energy community bonus credit percentage. See Energy community bonus credit rate , earlier, for more information.
If the energy storage technology was not placed in service within an energy community, leave line 3f blank, skip line 3g, and go to line 4.
Section C—Totals, Credit Reduction for Subsidized Energy Financing or Private Activity Bonds, and Credit Phaseout
Line 6
If proceeds of subsidized energy financing or private activity bonds were not used to finance your qualified clean electricity facility or your qualified energy storage technology, skip line 6, and go to line 7.
Credit reduction for Subsidized Energy Financing or Private Activity Bonds. The amount of the credit with respect to any facility or energy storage technology for any tax year will be reduced by the amount that is the product of the amount of the credit without the reduction for private activity bonds, for such year and the lesser of one of the following.
15%, or
A fraction. The numerator is the sum for the tax year and all prior tax years of proceeds of an issue of any obligations the interest on which is exempt from tax under section 103 and that is used to provide financing for the qualified facility or energy storage technology, as of the close of the tax year. The denominator is the aggregate amount of additions to the capital account for the qualified facility or energy storage technology for the tax year and all prior tax years, as of the close of the tax year.
Line 8
Elective payment phaseout for applicable entities. If you are making an elective payment election under section 6417 and the facility or energy storage technology doesn’t meet the rules of section 45Y(g)(12)(B)(i), doesn’t have a maximum net output of less than 1 MW (as measured in ac), or meet an exception under section 45Y(g)(12)(D), then multiply line 7 by the applicable
percentage of the year in which construction began below. All others, enter the amount from line 7.
Construction began in 2024, 90% (0.90).
Construction began in 2025, 85% (0.85).
Construction began after 2025, 0% (0.00).
Exception to elective payment phaseout. For facilities or energy storage technologies whose construction begins before the later of January 1, 2027, or the issuance of further guidance, Notice 2024-84 provides transitional procedures to claim the statutory exceptions to the elective payment phaseout related to the domestic content requirement.
To substantiate your claim of exception to the elective payment phaseout, you must complete and attach a statement to Form 3468. The statement must say, under penalties of perjury, that you have reviewed the requirements for the increased cost exception and the non-availability exception under section 45Y(g)(12) (D), and have made a good faith determination that the qualified investment meets the requirements for the increased cost exception and/or the non-availability exception, as applicable. The statement must be signed by a person with the legal authority to bind the applicable entity in federal tax matters. For more information, see Notice 2024-09 available at IRS.gov/irb/ 2024-02_IRB#NOT-2024-9 and Notice 2024-84 available at IRS.gov/irb/2024-50_IRB#NOT-2024-84 .
Line 10
Patrons, including cooperatives that are patrons in other cooperatives, enter the unused investment credit from the clean electricity investment credit allocated from cooperatives. If you are a cooperative, see the instructions for Form 3800, Part III, line 1v, for allocating the investment credit to your patrons.
Tip: See Cooperatives, earlier, for filing Form 3468 to report any unused credits from cooperatives.
Line 11
Partnership or S corporation. If you’re a partnership or S corporation electing to transfer the clean electricity investment credit with respect to a facility or property (or portion of) under section 6418(c), you must report the total credit amount on line 11 and Form 3800, Part III, line 1v.
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