IRS T.D.: Election to Transfer Certain Tax Credits Under the Inflation Reduction Act (IRC §6418)

Final regulations concerning the election under the Inflation Reduction Act of 2022 to transfer certain tax credits under I.R.C. §6418, the IRS released. The regulations describe rules: (1) for 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; and (2) related to a required IRS pre-filing registration process. These regulations affect eligible taxpayers that elect to transfer eligible credits in a taxable year and the transferee taxpayers to which eligible credits are transferred. Informed by the stakeholder feedback received in ...