Steptoe Memo July 10, 2025: Legal and Regulatory Risks Arising from Executive Order on “Beginning of Construction” Rules for Clean Energy Tax Credits
The July 10, 2025 memo analyzes legal and regulatory risks from the Executive Order on “beginning of construction” rules, highlighting potential impacts on 45Q, 45V, and other clean energy tax...
Download PDFJuly 2025
Legislative
November 2025
On August 12, the Carbon Capture Coalition sent a letter to the Department of the Treasury urging it to maintain the existing “beginning of construction” guidance and safe harbors for the Section...
Download PDFAugust 2025
Legislative
November 2025
The House passed legislation preserving 45Q for projects starting before 2033, but ends transferability after two years and bars certain foreign-controlled or influenced entities from claiming the...
Download PDFJune 2025
Letters & Comments
Regulatory & Guidance
Letter to Treasury on Recission of Subpart RR by the EPA co-signed by Coalition and CURC
Download PDFDecember 2025
The Coalition submitted comments urging the IRS and Treasury to align GHG emissions calculations for carbon capture, utilization, and storage (CCUS) projects under sections 45Y and 48E with the...
Download PDFAugust 2024
Regulatory & Guidance, Storage
January 2026
The Treasury and IRS released proposed regulations implementing the IRA’s technology-neutral production and investment tax credits (PTC/ITC) under sections 45Y and 48E, effective 2025 Unlike the...
Download PDFJune 2024
Letters & Comments
Regulatory & Guidance
February 2026