SECTION 1. PURPOSE
Internal Revenue Bulletin 2025-8 · 2026-10-03 edition · updated 2026-10-04 · United States
This notice provides an updated elective safe harbor for the domestic content bonus credit (First Updated Elective Safe Harbor) that modifies the safe harbor provided in IRS Notice 2024-41, 202424 I.R.B. 1615 (Notice 2024-41), including the table provided in section 4.04(1)(3) (Table 1), in the five ways described below in section 3 of this notice. Table 1 provided the Assigned Cost Percentages for each Manufactured Product and Manufactured Product Component to provide taxpayers clarity in applying the new elective safe harbor (New Elective Safe Harbor) outlined in Notice 2024-41. Taxpayers, including entities that make elective payment elections under § 6417 of the Internal Revenue Code (Code), 1 may elect to use the First Updated Elective Safe Harbor in lieu of
1 Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).
February 18, 2025 800 Bulletin No. 2025–8
the Domestic Manufactured Products and Components Cost and Total Manufactured Products Cost provisions of the Adjusted Percentage Rule in section 3.03(2)(b) and (c) of Notice 2023-38, 2023-22 I.R.B. 872 (Notice 2023-38), which require taxpayers to use the manufacturer’s direct costs of producing Manufactured Products and Manufactured Product Components in an Applicable Project. 2 Taxpayers who elect to use the First Updated Elective Safe Harbor for any Applicable Project must use one of the respective tables provided below in sections 5-7 of this notice subject to the conditions described in section 8 of this notice, also provided below.
Photovoltaic (PV) Ground-mount (Tracking and Fixed) Applicable Projects and one for PV Rooftop (MLPE and String) Applicable Projects, and providing updated associated cost percentages for each table (Updated Assigned Cost Percentages for PV Solar) 3, including those within the new columns in each table that provide a second set of associated cost percentages for employing PV modules that incorporate crystalline silicon photovoltaic (c-Si PV) cells and wafers that are manufactured in the United States. See sections 5.05 and 5.06 of this notice. The Updated Assigned Cost Percentages for PV Solar provided in the new columns specific to projects that use c-Si PV cells made with domestically produced wafers increase accuracy beyond Table 1 by accounting for the expected significant cost premium this type of cell would carry. There are no additional associated cost percentages for other types of PV cells because DOE assesses that the existing cost percentages, as updated in this notice, adequately capture the costs of other types of PV cells.
Second, section 6 of this notice modifies the Land-Based Wind Table from Table 1 by renaming the term (i) “Steel or iron rebar in foundation,” which is listed as an Applicable Project Component in Table 1, to “Steel or iron reinforcing products in foundation,” and (ii) the term “Material,” which is listed as a Manufactured Product Component in Table 1, to “Preform.” Regarding the associated cost percentages for land-based wind components, the First Updated Elective Safe Harbor’s values (Updated Assigned Cost Percentages for Land-Based Wind) are the same values as the Assigned Cost Percentages for the Land-Based Wind Table in Table 1. This notice uses the same values because DOE, using analysis from the national laboratories, found only minor changes in the component cost data underlying the Assigned Cost Percentages for the LandBased Wind Table in Table 1. For this reason, DOE did not independently publish updates to this data.
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