SECTION 4. COMPUTATION OF
Internal Revenue Bulletin 2008-34 · 2026-10-03 edition · updated 2026-10-04 · United States
CREDIT
.01 In General . The fuel cell credit for a taxable year is 30 percent of the basis of the qualified fuel cell energy property placed in service during the tax year. The microturbine credit for a taxable year is 10 percent of the basis of the qualified microturbine energy property placed in service during the tax year.
.02 Limitation of the Credit . The fuel cell credit for a taxable year cannot exceed $500 for each 0.5 kilowatt of capacity of qualified fuel cell energy property placed in service during the tax year. The microturbine credit for a taxable year cannot exceed an amount equal to $200 for each kilowatt of capacity of qualified microturbine energy property placed in service during the tax year.
.03 Coordination with Other Credits . The fuel cell credit and the microturbine credit are not allowed for that portion of the basis of a fuel cell power plant or stationary microturbine power plant which also qualifies for the rehabilitation credit under § 47(a). In addition, the credits are not allowed with respect to a fuel cell power plant or a stationary microturbine power plant for a taxable year if a credit under section 45 is allowed for the taxable year or any prior year for the electricity produced by such power plant.
.04 Reduction for Subsidized Energy Fi- nancing and Private Activity Bonds . The fuel cell credit and microturbine credit are reduced if the property qualifying for the credit is financed by subsidized energy financing or private activity bonds. Section 48(a)(4) provides rules for determining the amount of such reduction. For purposes of § 48(a)(4), subsidized energy financing does not include a grant includible in gross income under § 61, a nontaxable government grant, or a credit against state or local taxes.
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