Rules › IRS-2023-0028

Section 6418 Transfer of Certain Credits

Proposed rule from the Treasury Department, Internal Revenue Service (docket IRS-2023-0028). 69 comment letters from companies and organizations are listed below.

Agency
Treasury Department, Internal Revenue Service
Docket
IRS-2023-0028
Published
2023-06-21
Comments due
2023-08-14
Status
Comment period closed August 14, 2023 · no final rule found yet
Total public comments
87
Letters listed here
69
Joint letters
3, adding 7 more organizations as co-signers

Federal Register notice ↗ · Docket on Regulations.gov ↗

Who commented, by industry

Other 22 Energy, Mining & Utilities 20 Law, Accounting & Consulting 7 Advocacy & Nonprofits 7 Investment & Securities 4 Labor Unions 3 Environment & Conservation 2 Real Estate & Construction 1 Healthcare 1 Manufacturing & Chemicals 1 Transportation & Logistics 1

Who commented

Kirkland & Ellis LLP Company Law, Accounting & Consulting

filed 2023-08-17

Conservatives for a Clean Energy Future Company Energy, Mining & Utilities

filed 2023-08-17

Business Council for Sustainable Energy Trade or professional group Energy, Mining & Utilities

filed 2023-08-15

Carbon Utilization Research Council Trade or professional group Other

filed 2023-08-15

Securities Industry and Financial Markets Association (SIFMA) Trade or professional group Investment & Securities

filed as “Securities Industry and Financial Markets Association” · filed 2023-08-15

Hunton Andrews Kurth LLP Company Law, Accounting & Consulting

filed as “Hunton Andrews Kurth LLP (David S. Lowman, Jr. and Timothy L. Jacobs)” · filed 2023-08-15

National Association of Real Estate Investment Trusts (NAREIT) Trade or professional group Real Estate & Construction

filed as “Nareit” · filed 2023-08-15

Basis Climate Corp. Company Environment & Conservation

filed 2023-08-15

Dudley Ventures Company Investment & Securities

filed 2023-08-15

Energy infrastructure Council Trade or professional group Energy, Mining & Utilities

filed as “Energy Infrastructure Council” · filed 2023-08-15

GeoExchange Company Other

filed 2023-08-15

Solar Energy Industries Association (SEIA) Trade or professional group Energy, Mining & Utilities

filed as “Solar Energy Industries Association” · filed 2023-08-15
Joint letter, also signed by 1 organization: Building a Strong Solar Industry to Power America

United States Tax Credit Alliance Nonprofit or advocacy group Advocacy & Nonprofits

filed 2023-08-15

ALLETE, Inc. Company Other

filed 2023-08-15

Carbon Capture Coalition Trade or professional group Energy, Mining & Utilities

filed 2023-08-15

American Petroleum Institute (API) Trade or professional group Energy, Mining & Utilities

filed as “API” · filed 2023-08-15

Crux Company Other

filed 2023-08-15

Waste Pressure Corp. Company Other

filed 2023-08-15

Stellantis Company Other

filed 2023-08-15

Occidental Petroleum Corporation Company Healthcare

filed 2023-08-15

Tax Executives Institute, Inc. Company Advocacy & Nonprofits

filed as “Tax Executives Institute” · filed 2023-08-15

Blue Rock Renewables Company Other

filed 2023-08-15

New York State Bar Association Tax Section Trade or professional group Other

filed 2023-08-15

ACES Delta, LLC Company Other

filed 2023-08-15

The Tax Law Center at NYU Law and Roger Baneman (Advisor, NRDC) Nonprofit or advocacy group Advocacy & Nonprofits

filed 2023-08-15

Conservation Tax Credit Transfer and Tax Credit Connection Nonprofit or advocacy group Environment & Conservation

filed 2023-08-15

Ample Company Other

filed as “Ample, Inc.” · filed 2023-08-15

American Council on Renewable Energy Trade or professional group Energy, Mining & Utilities

filed as “American Council on Renewable Energy (ACORE)” · filed 2023-08-15

Cook Inlet Region Inc Company Other

filed 2023-08-15

Sheet Metal and Air Conditioning Contractors' National Association Trade or professional group Manufacturing & Chemicals

filed as “Sheet Metal & Air Conditioning Contractors' National Association” · filed 2023-08-15

Transferability Coalition Nonprofit or advocacy group Advocacy & Nonprofits

filed 2023-08-15

Zero Emission Transportation Association Trade or professional group Transportation & Logistics

filed as “Zero Emission Transportation Association (ZETA)” · filed 2023-08-15
Joint letter, also signed by 1 organization: United States Department of Treasury

Center for American Progress Nonprofit or advocacy group Advocacy & Nonprofits

filed as “Center for American Progress et. al” · filed 2023-08-15

Novogradac LIHTC Working Group Company Law, Accounting & Consulting

filed 2023-08-15

SunRaise Capital Company Investment & Securities

filed 2023-08-15

Taxpayers for Common Sense Nonprofit or advocacy group Advocacy & Nonprofits

filed 2023-08-15

Carbon America Company Other

filed 2023-08-15

Growth Energy Trade or professional group Energy, Mining & Utilities

filed 2023-08-15

Raise Green, Inc. Company Other

filed 2023-08-15

NextEra Energy, Inc. Company Energy, Mining & Utilities

filed 2023-08-15

PosiGen Inc. Company Other

filed 2023-08-15

North America's Building Trades Unions Labor union Labor Unions

filed as “North America’s Building Trades Unions (NABTU)” · filed 2023-08-15

RENEWABLE ENERGY TAX ADVISORS LLC Company Energy, Mining & Utilities

filed 2023-08-15

Husch Blackwell LLP Company Law, Accounting & Consulting

filed 2023-08-15

ACES Delta, LLC Company Other

filed 2023-08-15

Electric Drive Transportation Association (EDTA) Trade or professional group Energy, Mining & Utilities

filed 2023-08-15

Bright Spot Solar LLC Company Energy, Mining & Utilities

filed 2023-08-15

American Fuel and Petrochemical Manufacturers (AFPM) Trade or professional group Energy, Mining & Utilities

filed as “American Fuel and Petrochemical Manufacturers” · filed 2023-08-15

Center for Public Enterprise Nonprofit or advocacy group Advocacy & Nonprofits

filed 2023-08-15

Guzman & Company Company Other

filed 2023-08-15

American Clean Power Association Trade or professional group Energy, Mining & Utilities

filed 2023-08-15

Groom Law Group Company Law, Accounting & Consulting

filed 2023-08-15

American Federation of Labor and Congress of Industrial Organizations (AFL-CIO) Labor union Labor Unions

filed as “American Federation of Labor and Congress of Industrial Organizations” · filed 2023-08-15

Novogradac Renewable Energy Working Group Company Energy, Mining & Utilities

filed 2023-08-15

SMART and SMACNA Coalition or joint letter Labor Unions

filed 2023-08-15

GE Vernova Company Other

filed 2023-08-15

American Institute of CPAs (AICPA) Trade or professional group Law, Accounting & Consulting

filed as “AICPA” · filed 2023-08-15

Atheva, Inc. Company Other

filed 2023-08-15

Remora Carbon Company Other

filed 2023-08-11

Orsted Wind Power North America LLC Company Energy, Mining & Utilities

filed 2023-08-11

Edison Electric Institute (EEI) Trade or professional group Energy, Mining & Utilities

filed as “Edison Electric Institute” · filed 2023-08-11

Evergrow Inc. Company Other

filed 2023-08-11

Oregon Solar and Storage Industries Association Trade or professional group Energy, Mining & Utilities

filed 2023-08-11

Navigator CO2 Ventures Company Investment & Securities

filed as “Navigator CO2 Ventures LLC” · filed 2023-08-11

CFO Services Company Other

filed 2023-08-11

CFO Services Company Other

filed 2023-08-11

Oregon Clean Power Cooperative Company Energy, Mining & Utilities

filed 2023-07-28

Baker Tilly US LLP Company Law, Accounting & Consulting

filed as “Baker Tilly” · filed 2023-07-25

Obsido Solar Company Energy, Mining & Utilities

filed 2023-07-18