IRA Energy Credits, Part 2: Proposed Regs and What’s Next

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In the second of a two-episode series, Tim Jacobs of Hunton Andrews Kurth continues his discussion of the energy credits enacted in the Inflation Reduction Act and the proposed regulations.

Listen to the first part of this series: IRA Energy Credits, Part 1: History and Early Guidance

For additional coverage, read these articles in Tax Notes:

In our “Editors’ Corner” segment, Michael Semes, professor of practice in the graduate tax program at the Charles Widger School of Law at Villanova University and of counsel at BakerHostetler, chats about his coauthored Tax Notes piece, “ADP Certiorari Denial Increases SaaS Uncertainty.”

Follow us on Twitter:

David Stewart: @TaxStew
Tax Notes: @TaxNotes

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This episode is sponsored by the University of Cincinnati. For more information, visit online.uc.edu/taxation.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

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Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

This transcript has been edited for length and clarity.

David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: energy boost, part 2.

We're continuing our deep dive from last week into the energy credits enacted under the Inflation Reduction Act. The first part, which you should definitely listen to before this one, lays the groundwork for the credits and what's to come in this episode. Tax Notes contributing editor Marie Sapirie will be back again in just a minute to tell us more about this.

Later in the episode, we'll hear from Tax Notes State author Michael Semes about his article series on an Arizona Court of Appeals holding in ADP LLC v. Arizona Department of Revenue.

But first, Marie, welcome back to the podcast.

Marie Sapirie: Thanks for having me.

David D. Stewart: Could you give us a quick recap of who you talked to and what was discussed in the first episode of the series?

Marie Sapirie: I spoke with Tim Jacobs from Hunton Andrews Kurth. In the first episode, we talked about the history of the Inflation Reduction Act's energy tax credit changes and the implementation process to date.

David D. Stewart: And what can we look forward to in part 2?

Marie Sapirie: In this part, we'll hear Tim's insights on the domestic content rules and the prevailing wage and apprenticeship requirements. We conclude with a look at what guidance is expected next.

David D. Stewart: All right, let's go to that interview.

Marie Sapirie: Tim, welcome back to the podcast.

Timothy L. Jacobs: Marie, great to be here.

Marie Sapirie: In sections 45, 45Y, 48, and 48E, there's a bonus for the use of domestic content in applicable energy projects. And as mentioned earlier, the IRS and Treasury put out Notice 2023-38 in June explaining the rules they intend to include in proposed regulations. Would you tell us about the bonus credit, what the notice added, and what we should look for in the proposed regulations?

Timothy L. Jacobs: So the Notice 2023-38 came out on May 12. The initial guidance came out in the form of an IRS notice, and the domestic content provisions themselves that Congress enacted, which is section 45(b)(9), is the primary provision but also applies, as you said, under section 48, referenced the Buy America Act regulations, which are 49 CFR 661. They were incorporated, those rules were incorporated into the domestic content provisions.

And what the bonus credit does is I like to think of it in terms of the investment tax credit. It is essentially a 10 percent bonus credit on top of the base 30 percent credit that's normally available for investment tax credit. But you go over to the production tax credit and it's essentially a 10 percent bonus credit on top of the normal credit rate that applies under that provision for production tax credits.

But essentially, there are three components that are involved. The notice calls them "applicable project components," but it's steel or iron and then it's manufactured products. Those are the three items that the statute focuses on. There are also, of course, unmanufactured items, which would be items that come to the site or that are at the site, such as concrete and so forth, that are not necessarily covered by the statute itself or incentivized by domestic content.

But the way that the rules work is you have to have 100 percent U.S. manufactured steel, which is steel or iron, and that is consistent with the rules under the Buy America Act, which 49 CFR 661.5 actually has specific rules regarding steel or iron. The notice, Notice 2023-38, correctly concludes that when we're talking about steel or iron and that 100 percent requirement, it is structural steel or iron. It is not items that are component parts of manufactured products that may be steel or iron. And that is an important distinction.

Manufactured products, the way the statute is worded and the way that the Buy America Act is applied, is at the component level. Buy America and the regulations were promulgated by the Federal Transit Administration, and the Federal Transit Administration generally has three levels of categorization. One is the end product, then it's the components, and then it's the subcomponents, and generally the subcomponents are disregarded, and you look to the component level to measure out the appropriate percentage for purposes of the statute.

Here it is 40 percent. Do you have domestic content at 40 percent at the component level? Notice 2023-38, however, basically divides up the statutory provisions into interpretation that is at the applicable project component level and then what they call manufactured product components.

Manufactured product components resemble very closely subcomponents because they are items that are directly incorporated into the manufactured product. And so there's a question mark, which has, say, enveloped the industry, which is why Treasury and IRS adopted what is essentially a subcomponent analysis when that particular analysis is not used in the Buy America Act.

Typically, subcomponents are disregarded in the equation or in the calculation of domestic content. Since May and the issuance of the guidance, there have been a number of commentary; I think actually you wrote an article that was called "the Domestic Content Quandary," which actually describes some of the issues with financing projects with actually capitalizing on the domestic content bonus credit.

And some of the issues that you see that have been caused by the notice I think are really twofold. One is that focus on subcomponents, which are the manufactured product components, and then also the requirement that manufacturer's costs are what are used in the calculation of the so-called domestic manufactured products and components cost, the adjusted percentage rule calculation, as I would say.

It's the domestic cost percentage. That that calculation uses the manufacturer's direct cost. It does not use the taxpayer's cost. Taxpayer's cost would be the cost that is paid for the manufactured product that is delivered to the site. And so what we see in this notice is manufacturers are not willing to disclose their cost because of competitive advantage and issues of profit margins and revelation of profit margins. And so you're left with a program under domestic content that, it's still in the works, let's say.

Lots of stakeholders have tried to discuss the issue with Treasury, with Department of Energy, with the White House to come up with a way to move past manufacturer's cost. And it's not just manufacturer's cost, it's direct cost, the manufacturer's direct cost, which currently do not exist and are not tracked in the same manner that the notice itself requires. So you see manufacturers having to move at this point to a new system of accounting to actually come up with those costs.

You have a hesitation by manufacturers to actually disclose those costs, and then you also have investors and the tax equity market and transferees dealing with that issue to understand how to capture domestic content bonus credit when manufacturers may or may not be willing to disclose their books and records that reveal those costs.

Then you also have what is in this notice a safe harbor — or it's described as a safe harbor — which is a table that includes solar battery energy storage systems, both onshore wind and offshore wind. There is a listing which is of some of the applicable project components and a listing of some of the manufactured product components, and then also certain items that are categorized as steel or iron.

But what's not in the tables that the IRS notice has is it does not include some of what you would understand are under the definitions were maybe perhaps the unlisted components — the unlisted applicable project components and the unlisted manufactured product components.

And there's a question mark: What do you do if an item that you know is part of a solar project or part of a wind project is not listed in the table? Do you have to take that into account because of the definition of applicable project component, manufactured product component? Or is that excluded because it's not listed in the table because Treasury, Department of Energy and FTA, Federal Transit Administration, didn't include it? And so there's a discussion at the moment, is this really a safe harbor? Does it really provide a safe harbor with respect to those unlisted items? These are all issues that are being discussed.

And the question mark is, what is Treasury going to do here? Is Treasury going to issue an IRS notice, which they can do right now? Treasury and IRS could issue or update the notice to provide additional information to clarify certain issues that have been troubling the industry. They could issue an IRS notice in short form to adjustments to the original notice or to essentially provide a separate safe harbor.

They could do that immediately. There's also discussion whether they will move to a notice of proposed rulemaking, which would be the next logical step given that Notice 2023-38 was a notice of intent to propose regulations.

The timing of that is critical because right now everyone is in discussions and negotiations about doing transactions, building projects. And so timing is critical. It does take time to issue proposed regulations, but right now there is not clarity on what Treasury will actually do, whether they issue a notice before the end of this year or in the very near future, or whether they will actually move directly to proposed regulations and are working on those, or I do understand they are working on proposed regulations.

But whether they can issue those proposed regulations in the near term to be very helpful to the industry, I do hope the answer is they will be moving quickly in the next short period.

Marie Sapirie: Under the IRA, taxpayers who satisfy prevailing wage and apprenticeship requirements can claim increased credit amounts under a number of code sections and an increased deduction under section 179D. Would you give us an overview of the new requirements, as well as what the proposed regulations added to the understanding of the prevailing wage and apprenticeship rules?

Timothy L. Jacobs: Yeah, so it's important to understand that the prevailing wage and apprenticeship rules are — they're almost in every single tax credit of relevance at least to large taxpayers and investors. The only provisions that do not have prevailing wage and apprenticeship that we've talked about would be 45X, the advanced manufacturing credit. But pretty much every credit that is relevant or that I've discussed here actually does have these labor requirements. And they originate by congressional reference in the IRA to the Davis-Bacon Act.

The Davis-Bacon Act goes back, I believe, to the 1930s roughly, 1931. It has been in the federal system for almost 100 years now. Regulations have been in existence for some time, but there was more recently a rewrite of those regulations and a finalization of the regulations. But Davis-Bacon Act applies to public buildings and public works, and the set of rules that apply there require prevailing wages to be paid to laborers and mechanics. And that is an offshoot of the fact that the federal government is paying for those public buildings and works. And as a result of that, insisting on prevailing wages.

The IRA incorporates those Davis-Bacon Act rules by reference with respect to wage determinations, and what the proposed regulations do that were issued in August is one of the first things they do is actually tell you that they are not following the Davis-Bacon Act in its entirety, but that the Davis-Bacon Act rules and regulations and authorities would apply with respect to the determination of wage, determinations by the Department of Labor, and at certain definitions, key definitions such as laborers and mechanics, what are laborers and mechanics, what is considered to be a site of the work, those types of definitions.

Some of the key definitions that come out of the regulations under Davis-Bacon, that those would also apply to the prevailing wage and apprenticeship rules for tax purposes. The Treasury was guarded in saying that they would not wholesale bring in Davis-Bacon Act, but only where it was appropriate for administrative purposes. And I think that's key.

Although when you review the actual language that's embodied in these proposed regulations, you come away with the pretty clear impression that the proposed regulations were heavily influenced by the Davis-Bacon Act regulations and by the Department of Labor rules.

And I say that for one reason because the Davis-Bacon Act regulations, after an extended period of time, they were outstanding for almost a year and a half, but they were finalized I believe it was August 23 when they ended up on the federal register, August 23, 2023, and then the prevailing wage and apprenticeship rules come out on August 30, 2023.

So seemed pretty clear to me that the prevailing wage and apprenticeship rules or regulations were certainly not mirror image, but they were following closely the Davis-Bacon Act.

Marie Sapirie: Are there any outstanding issues on the prevailing wage and apprenticeship rules that we should look for in future guidance?

Timothy L. Jacobs: Comments are due on October 30. I'm working on a set of comments for various clients myself, but I think that some of the key issues relate to the apprenticeship requirement. The apprenticeship requirement I would say is you have to have qualified apprentices. There are basically three requirements. There's really two requirements and one tripwire, I'd say. There's a labor hours requirement, then there's a participation requirement, and then there is a journey-worker-to-apprentice ratio requirement, which is the tripwire

But the apprenticeship requirement is the item that I think has generated the most attention and the most issues because it is not as grounded in the Davis-Bacon Act. And I believe you actually wrote an article most recently entitled "Apprentices and Emergency Repairs." It talks about some of the items that we expected that would've been addressed in the proposed regulations but which are creating problems. The statute for apprenticeship requirement uses the term with respect to the construction of the qualified facility.

The other language that's in there is construction, alteration, or repair. And when you go to 45(b)(7), which is the prevailing wage requirement, that provision actually breaks down construction from alteration or repair. Construction is before the placed-in-service date. Alteration or repair is described as after the placed-in-service date. And that is with respect to the 10-year credit period for PTC purposes, the production tax credit purposes. But one of the key issues is this language that's in the apprenticeship requirement, which is under 45(b)(8). It does not have that same breakdown, but it uses the words with respect to construction.

Now, Congress, when it enacted the statute, obviously used those words with intent, and I think the correct reading is that the apprenticeship requirement applies before the placed-in-service date during the construction period and does not apply to the operational period during the 10-year credit period for the reasons that you actually stated in the article regarding emergency repairs.

Going out and requesting an apprentice and bringing an apprentice in during the operational period is very different. It's a different paradigm than it is during the construction period when you can anticipate the need, you can go to the qualified program and make the request and such and so forth.

One of the other issues is what I'll call preliminary activities. Those activities that for tax purposes are not considered construction per se. They do not count towards beginning of construction, things like site grading, demolition, clearing of the land, those types of items.

Those actually may be covered by the Davis-Bacon Act, but they do not count as beginning of construction. And so they are considered to be preliminary activities. They don't count. When you move to excavation and firm land grading, then that's different. You start actually pouring concrete, that's beginning of construction. Lots of notices under that, starting with [Notice] 2013-29, etc.

The issue that was not raised or not addressed necessarily in the proposed regs, but what I understand actually was addressed in the ABA tax section, the video conference with Treasury, is what do you do with those preliminary activities if they started before the January 29, 2023, date? January 29, 2023, date is the date that 60 days after the original notice was issued for prevailing wage.

And the clarity that came out is that those preliminary activities that might've occurred before January 29, that would not allow you to grandfather in or allow you to move in under 45(b)(6) to say you have begun construction and therefore don't have to apply prevailing wage and apprenticeship, that those preliminary activities that they began before January 29, 2023, they're not covered by prevailing wage apprenticeship. It's actually going forward. I think that's the correct answer in that respect.

But there's another question, which is, if those preliminary activities are not construction for tax purposes, then those preliminary activities really should not track prevailing wage apprenticeship rules in the first place. So I think that's an easier answer.

There are a number of other issues that I think were addressed in the proposed regs. We now have, the curative payment rules are laid out, how you cure a failure to pay prevailing wage, how you cure a failure to request apprentices, what the process is, the involvement of Department of Labor. There are wage determination rules. There's the general wage determination, and there's the supplemental wage determination rules. All of that is laid out in what are fairly detailed regulations.

I would say that there are still many areas that remain open, but some of the key issues do revolve around the apprenticeship rules and then also with respect to good faith, effort exception, and these curative payment provisions.

Marie Sapirie: So to conclude, what's the next major piece of the implementation that we should expect?

Timothy L. Jacobs: So I think they've signaled that they're — I think it's called phase 2. So the assistant secretary, I believe, on September 8, 2023, said that they're moving towards the manufacturing credits, and that's 45X and 48C. And I'd also throw in there the clean hydrogen credit. Those are the three items that I'm looking for. It's 45X, 48C, and 45B. 48C, the guidance is already out, but the process of allocation is ongoing right now. 45X I think we're going to see proposed regulations very soon.

And in 45B, I believe we will see clean hydrogen; we will see guidance towards the end of this year. I think the other major question is, as I said before, is Treasury going to act on domestic content quickly? And as I said, I think it is actually imperative that Treasury move quickly to either issue an updated notice of intent, in particular with respect to technologies that are not listed in the tables that they included in Notice 2023-38, or they don't actually issue the proposed rule or regulations. We would hope that they do that very quickly on domestic content.

Marie Sapirie: Well, thank you for joining the podcast today.

Timothy L. Jacobs: All right, thank you.

David D. Stewart: And now, coming attractions. Each week we highlight new and interesting commentary in our magazines. Joining me now is Acquisitions and Engagement Editor in Chief Paige Jones. Paige, what do you have for us?

Paige Jones: Thanks, Dave. In Tax Notes Federal, Kyle and Shuting Pomerleau explore four carbon tax revenue swaps that would expand the child tax credit. Edward Zelinsky argues that the contemporary nonprofit hospitals function more like their for-profit competitors and should be taxed in the same way.

In Tax Notes State, Brakeyshia Samms reviews this year's state tax actions that either helped or hindered racial equality. Brett Carter highlights a Tennessee court holding that software is a nontaxable intangible.

In Tax Notes International, Suranjali Tandon and Chetan Rao explained the potential importance of amount B for developing countries. Sylvia Song explains Malaysia's new transfer pricing rules and reviews key changes.

In Featured Analysis, Robert Goulder considers the UK tax fraud case against former Formula 1 boss Bernie Ecclestone.

On the opinions page, Carrie Brandon Elliot provides an overview of federal resources available to help taxpayers fight identity theft and tax refund fraud scams.

And now for a look at what's new and noteworthy in our magazines, here is Tax Notes State Editor in Chief Audrey Pollitt.

Audrey Pollitt: Thanks, Paige. I'm here with Michael Semes, a professor of practice in the graduate tax program at the Charles Widger School of Law at Villanova University and of counsel at BakerHostetler. Welcome to the podcast, Mike.

Michael J. Semes: Thanks very much, Audrey. It's great to be here.

Audrey Pollitt: We're here to discuss your Tax Notes State article "ADP Certiorari Denial Increases SaaS Uncertainty," a conclusion of a three-part series partially coauthored with Matthew Sommer that analyzes the Arizona Court of Appeals' holding in ADP LLC v. Arizona Department of Revenue.

In the opinion, the appellate court concluded that ADP's licensing contracts with Maricopa County for access to its attendance tracking software eTime are subject to both state and local transaction privilege taxes.
ADP maintains that the court erred in concluding that software as a service is taxable as tangible personal property as defined in the TPT statute, a conclusion with which your articles ardently disagree. Why?

Michael J. Semes: Yeah. Here's my take on this is that the Arizona Court of Appeals, with all due respect to them and their judgment and their wisdom, looked at the definition of tangible personal property, which under the Arizona statute, like many other state statutes, says that tangible personal property is, and I'm paraphrasing, anything that is perceptible to the senses.

And they use that definition or interpreted that definition to conclude that software as a service, SaaS as we know it, is perceptible to the senses.

And before we get into all of the fallout that can come from a decision like that, I just question how they got there. This case looked to two cases that were decided 30, 40 years ago, one dealing with putting a coin into a jukebox and another putting a coin into a washing machine. And those cases concluded that the taxpayer in that instance was purchasing or leasing tangible personal property because they were using a phonograph and they were using a washing machine.

And based on that, Court of Appeals said, "Hey, therefore the washing machine was a service and the phonograph was not only a phonograph, but it was perceptible to the ears, it was oral. And therefore, in the same way, SaaS is perceptible to the senses." And I just find that being a real stretch. Because in both of those instances, you had a tangible product. You had a phonograph. You had a washing machine. In the phonograph situation, you didn't have to go to say, "Oh, Frank Sinatra's voice was being heard when the record was being played." You didn't need to go there. All you had to do was say, "Look, if it was the use, lease, rental, whatever you want to call it, of tangible personal property, a phonograph." That is not at all what was going on here with ADP's eTime SaaS.

Here, ADP, before they broke out selling eTime, was performing those same services manually. And when they were performing them manually, they were not subject to tax. So that causes one to ask, so why is it that they're being now performed electronically causes them to be subject to tax?

And I just think that that doesn't make any logical sense. And moreover, in this instance, ADP separately stated them. And so by separately stating them, I think that that makes it all the more rational that they really were part of the entire bundle of services that were being performed, but they were being performed electronically instead of manually. And so what's the difference? They really shouldn't be subject to tax.

Audrey Pollitt: In your first article, and I'm paraphrasing, it seemed as though you were characterizing the court's statutory interpretation as both questionable and as a judicial fabrication of legislative intent to stretch the definition of tangible personal property to reach a desired conclusion. Do you deem that conclusion to be merely to pull more tangible personal property into state and local taxing jurisdictions, or do you also cite other motivators?

Michael J. Semes: Well, yes, I do believe that it was questionable, and I've explained why. And going to the legislative intent issue, I question how they could say that the Legislature intended for SaaS to be treated as tangible personal property. Because I mean, let's not be naive. It was enacted initially in the '30s or '40s. And even if it had been reenacted and just not amended in the '70s, '80s, '90s, how could one really say that the Legislature intended for SaaS to be treated as tangible personal property?

No legislator that I know of back in even the '90s could have imagined SaaS or software being accessed on a server to be. If they couldn't even have imagined it, and maybe that's the point, they couldn't imagine it, but it was perceptible through some sort of imagination. Jules Verne predicting, Dick Tracy predicting iPhones and watches being used back in the '60s. That's the only way that it would've been perceptible, and that's why I said I think they're fabricating legislative intent.

Audrey Pollitt: So then in the second installment, you described some of the significant unintended consequences and questions born of this decision, and I think that overbreadth and uncertainty around applications seem to be the themes that you pull through this final installment as well. But in the final installment, you also propose a way to limit the damage caused by this decision. Can you talk a little bit about what you proposed to mitigate this uncertainty?

Michael J. Semes: Yeah, I think that this case should be a warning, if you will, for taxpayers and tax administrators, all stakeholders, legislators. Because as I mentioned in the second article, the fallout could be disastrous. What I think that that would need to involve is for legislators, taxpayers, and tax administrators, all stakeholders sitting around the table and discussing what they want to have subject to tax.

And I don't know whether it comes before or after that discussion, but then the people from the industry, taxpayers, need to educate legislators and tax administrators who aren't. And it's not through their own fault, it's not their job, but they don't understand the complexities and the details of how SaaS or other technologies or what other types of things that a legislature may want to subject to tax. They don't understand the business.

So I think it's incumbent upon taxpayers to educate tax administrators and legislators and do it in a way where they're working together and say, "Look, here's how our business works. We don't want this to be subject to tax. But if you in your infinite wisdom decide that it should be subject to tax, let's at least reduce the amount of uncertainty and understand what it is that's being subject to tax."

Then taking that a step further, legislators — and this would create an additional onus on legislators, additional work for legislators — what they need to do is they also need to think a few steps ahead, just like the Joint Committee on Taxation at the federal government level does. They're always thinking three or four steps ahead. And state legislators need to think and say, "OK, how do I define this? Do I put an exclusive list of items? If I put an exclusive list and not an inclusive list, then I know that that list is not going to be expanded."

So that creates work for the legislature to define that list. It also creates work for the legislators and tax administrators and taxpayers that in the future, if the legislature decides they want to expand that list, then all those stakeholders in my view should get together again and say, "OK, the list may expand. Let's define clearly how it is going to expand." Like I said in my article, it's kind of like the Fram oil filter man.

The legislatures and all the stakeholders can pay $4 for an oil filter now or $200 for a big repair later. And so it would require work upfront from all the stakeholders, but that work, an ounce of prevention is worth a pound of cure, it would then reduce the amount of uncertainty, reduce the amount of senseless, needless litigation going forward.

Audrey Pollitt: It sounds like it would serve both judicial and administrative economy. Are there any groups working in that space? I know that you mentioned in your final installment the MTC's work group on digital products. Could you talk about that?

Michael J. Semes: Yes. The MTC and the Streamlined Sales Tax Project are working toward this, and again, they have a lot of people from industry involved. But I think for whatever reason, it just doesn't seem that their work is bearing fruit. I don't know what the reason for that is, but I applaud them for what they're doing, and I encourage them to keep it up because I think that that's the right thing to do. And if we do more of it, maybe we will achieve a goal of more certainty sooner rather than later.

Audrey Pollitt: And before we let you go, Mike, where can listeners find you online?

Michael J. Semes: Thanks for asking that, Audrey. People can find me on LinkedIn, on the BakerHostetler website, and also on the Villanova School of Law Graduate Tax Program website.

Audrey Pollitt: Thank you for joining us on the podcast, Mike.

Michael J. Semes: Thank you, Audrey. It's been my pleasure.

Audrey Pollitt: You can find Mike's coauthored article online at taxnotes.com, and be sure to subscribe to our YouTube channel, Tax Notes, for more in-depth discussions on what's new and noteworthy. Again, that's Tax Notes with an S. Back to you, Dave.

David D. Stewart: That's it for this week. You can follow me online @taxstew, that's S-T-E-W, and be sure to follow @taxnotes for all things tax. If you have any comments, questions, or suggestions for a future episode, you can email us at podcast@taxanalysts.org. And as always, if you like what we're doing here, please leave a rating or review wherever you download this podcast. We'll be back next week with another episode of Tax Notes Talk.

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Tax Notes Talk

IRA Energy Credits, Part 2: Proposed Regs and What’s Next

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