IRS Prop. Reg.: Guidance on Election to Transfer Certain Credits under Inflation Reduction Act (IRC §6418)

Proposed regulations regarding the election under the Inflation Reduction Act of 2022 to transfer certain federal income tax credits, the IRS released June 14. I.R.C. §6418 allows “eligible taxpayers” to elect to transfer certain credits to unrelated taxpayers rather than using the credits against their federal income tax liabilities. The proposed regulations would describe the election to transfer eligible credits in a taxable year, including definitions and special rules applicable to partnerships and S corporations and regarding excessive credit transfer or recapture events. Comments are due Aug. 14, 2023, and a public hearing is scheduled for Aug. 23, 2023, at ...