Notice 2023-18 established the program under § 48C(e)(1) of the Internal

Revenue Code (Code) to allocate $10 billion of credits ($4 billion of which may be allocated only to projects located in certain energy communities) (§ 48C credits) for qualified investments in eligible qualifying advanced energy projects (§ 48C(e) program).

For purposes of § 48C credit allocations under the § 48C(e) program, § 48C(e)(4) (A) provides a base credit rate of 6 percent of the qualified investment (as defined in § 48C(b)). In the case of any project which satisfies the requirements of § 48C(e)(5) (A) and (6) (prevailing wage and apprenticeship requirements), § 48C(e)(4)(B) provides an alternative rate of 30 percent of the qualified investment.

The Treasury Department and the IRS provided two allocation rounds under the § 48C(e) program. For the second allocation round (Round 2) of the § 48C(e) program, which began on May 22, 2024, the IRS allocated approximately $6 billion ¹ of the § 48C credits with approximately $2.5 billion in § 48C credits allocated to projects in designated energy communities. Section 70515 of Public Law 119-21, 139 Stat. 72, 276 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), amended § 48C(e)(3)(C) to limit the avail

ability of previously allocated § 48C credits that were subsequently revoked for future § 48C(e) program allocations.