Coalition Letter to Treasury and IRS Urging Updated Guidance - American Commitment

American Commitment submitted formal comments to the Internal Revenue Service urging revisions to outdated IRS notices to align with the One Big Beautiful Bill Act and President Trump’s Executive Order 14315. These changes are critical to ensure that the wind and solar subsidies ended under the new law cannot be revived through loopholes or broad safe harbors. Here is a portion of that letter, and you can read the full letter here.

 

Dear Secretary Bessent,

We respectfully request that the Internal Revenue Service revise IRS Notices 2013-29, 2013-60, 2014-46, 2015-25, 2016-31, 2017-4, and 2021-41 to align with the statutory provisions enacted under the One Big Beautiful Bill Act (H.R. 1, “OBBBA”).

Background and Statutory Context

The One Big Beautiful Bill Act (OBBBA) sunsets the generous subsidies for wind and solar generation in the Clean Electricity Production Credit and the Clean Electricity Investment Credit of the Inflation Reduction Act of 2022 (IRA). The law, however, does not define some key provisions. President Trump signed the OBBBA into law on July 4, 2025. Subsequently, on July 7, 2025, the president signed Executive Order 14315 (“Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources”), which directs the Secretary of the Treasury to “take all action as the Secretary of the Treasury deems necessary and appropriate to strictly enforce the termination of the clean electricity production and investment tax credits under sections 45Y and 48E of the Internal Revenue Code for wind and solar facilities…”