SECTION 1. PURPOSE
Internal Revenue Bulletin 2023-10 · 2026-10-03 edition · updated 2026-10-04 · United States
.01 This notice establishes the program under § 48C(e)(1) of the Internal Reve nue Code (Code) 1 to allocate $10 billion of credits ($4 billion of which may be allocated only to projects located in cer tain energy communities) for qualified in vestments in eligible qualifying advanced energy projects (§ 48C(e) program). The goal of the § 48C(e) program is to ex pand U.S. manufacturing capacity and quality jobs for clean energy technologies (including production and recycling), to reduce greenhouse gas emissions in the U.S. industrial sector, and to secure do mestic supply chains for critical materials (including specified critical minerals) that serve as inputs for clean energy technolo gy production.
.02 This notice and its appendices pro vide the initial program guidance for the § 48C(e) program. The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue a supplemental notice and appendi ces (additional § 48C(e) program guid ance) by May 31, 2023.
.03 The Treasury Department and the IRS anticipate providing at least two allocation rounds under the § 48C(e) program. For the first allocation round (Round 1) of the § 48C(e) program, which will begin on May 31, 2023, the Treasury Department and the IRS antic ipate allocating $4 billion of qualifying advanced energy project credits (§ 48C credits) with approximately $1.6 billion in § 48C credits to be allocated to proj ects located in certain energy communi ties. Although the Treasury Department and the IRS intend to allocate a total of $10 billion of § 48C credits with not less than $4 billion of § 48C credits to proj
ects located in certain energy commu nities over the duration of the § 48C(e) program, depending upon applications received, the Treasury Department and the IRS may not allocate exactly 40 per cent of the total § 48C credits allocated in Round 1 to projects located in certain energy communities. To be considered for an allocation of § 48C credits in the § 48C(e) program for Round 1, taxpayers must submit concept papers to the De partment of Energy (DOE) by July 31, 2023. Following submission of a concept paper, DOE will encourage or discourage taxpayers from submitting a joint appli cation for DOE recommendation and for IRS § 48C(e) certification (§ 48C(e) ap plication).
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