Notice 2024-9, page 358.

The notice of intent to propose regulations concerns the statutorily-required exceptions to the elective payment phaseout for entities that do not satisfy the domestic content requirements of §§ 45, 45Y, 48 and 48E. This notice provides the transitional process by which the IRS will implement the statutorily-required exceptions to the elective payment phaseout for entities that do not satisfy the domestic content requirements of §§ 45, 45Y, 48 and 48E. These transitional procedures only apply to projects that begin construction prior to January 1, 2025. This notice also requests comments to inform the development of the forthcoming proposed regulations that will implement the process by which the statutorily-required exceptions will be provided to these phaseouts if construction begins on or after January 1, 2025.