SECTION 10. SUBSTANTIATION

A taxpayer reporting a domestic content bonus credit amount for meeting the Domestic Content Requirement must meet the general recordkeeping requirements under § 6001 to substantiate that the Domestic Content Requirement has been met. Section 6001 provides that every person liable for any tax imposed by the Code, or for the collection thereof, must keep such records as the Secretary of the Treasury or her delegate may from time to time prescribe. Section 1.60011(a) provides that any person subject to income tax must keep such permanent books of account or records as are sufficient to establish the amount of gross income, deductions, credits, or other matters required to be shown by such person in any return of such tax. Section 1.60011(e) provides that the books and records required by § 1.6001-1 must be retained so long as the contents thereof may become material in the administration of any internal revenue law. See also §§ 45(b)(12), 48(a)(16), 48E(a)(3)(B) (by cross-reference to § 48(a)(12)), and 45Y(f).

14 The two modifications of Table 2 in Notice 2024-41 are (1) adding the Applicable Project “Hydropower Facility, or Pumped Hydropower Storage Facility” and its associated list of Appli- cable Project Components and categorizations and (2) replacing “Utility-scale photovoltaic system” with “Ground-mount and rooftop photovoltaic system.”

February 18, 2025 812 Bulletin No. 2025–8

tion of which begins before the date that is 90 days after the date of publication in the Federal Register of proposed regulations on the domestic content bonus credit requirements.

Taxpayers may rely on Notice 2024-41, in its entirety and as modified by section 4 of this notice, for the domestic content bonus credit requirements for any Applicable Project, the construction of which begins before the date that is 90 days after the effective date of this notice.

Effective January 16, 2025, taxpayers may rely on the First Updated Elective Safe Harbor and the guidance provided in this notice for the domestic content bonus credit requirements for any Applicable Project the construction of which begins before the date that is 90 days after any future modification, update, or withdrawal of the First Updated Elective Safe Harbor.

Where taxpayers may rely on either the New Elective Safe Harbor of Notice 2024-41 or the First Updated Elective Safe Harbor in this notice, a taxpayer may apply only one of the above-referenced safe harbors, and its associated cost percentages, and use it exclusively.

Taxpayers may treat the classifications of any Applicable Project Components or Manufactured Product Components that are listed within the tables provided in sections 5-7 of this notice as also being listed in Table 2 of Notice 2023-38. To the extent Table 2 of Notice 2023-38 and the tables provided in sections 5-7 of this notice are inconsistent regarding the classification of Applicable Project Components or Manufactured Product Components, the taxpayer may elect which set of classifications to use and must consistently apply the related classifications to all the other Applicable Project Components or Manufactured Product Components of the Applicable Project.

ical bills in certain circumstances. This notice was drafted in consultation with the Departments of Labor and Health and Human Services. Similar guidance for items and services furnished during 2022, 2023 and 2024 was published in Revenue Procedure 2022–11, Notice 2022–11, Notice 2023–4 and Notice 2024–1. ²