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IRS, Treasury finalize rules on clean energy tax credit transfers

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The Internal Revenue Service and the Treasury Department released final regulations Thursday on the transfer of clean energy manufacturing, investment and production tax credits, with specific rules for partnerships and S corporations. 

The rules aim to increase investment in clean energy technologies by making tax incentives transferable between project developers and investors. The Inflation Reduction Act created two new credit delivery mechanisms — elective pay (otherwise known as “direct pay”) and transferability — that allow state, local and tribal governments; nonprofit organizations; Puerto Rico and other U.S. territories; and other businesses to leverage clean energy tax credits. Until the Inflation Reduction Act introduced these new credit delivery mechanisms, governments, many types of tax-exempt organizations, and many businesses couldn’t fully utilize tax credits like those that incentivize clean energy construction. The 2022 law has spurred development of energy tax credit exchanges. Some of the incentives were already available to businesses under the CHIPS and Science Act of 2022.

“The Inflation Reduction Act’s new tools to access clean energy tax credits are a catalyst for meeting President Biden’s historic economic and climate goals,” said Treasury Secretary Janet Yellen in a statement. “They are acting as a force multiplier, enabling companies to realize far greater value from incentives to deploy new clean power and manufacture clean energy components. More clean energy projects are being built quickly and affordably, and more communities are benefitting from the growth of the clean energy economy.”

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Janet Yellen, U.S. Treasury secretary, speaks during a news conference at the Treasury Department in Washington, D.C.

Ting Shen/Bloomberg

The Inflation Reduction Act and the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act allow taxpayers to take advantage of some of manufacturing investment, clean energy investment and production tax credits through elective pay or transfer provisions. For tax years starting after Dec. 31, 2022, eligible taxpayers can opt to transfer all or part of eligible credits to unrelated taxpayers for cash payments.

The unrelated taxpayers are then permitted to claim the transferred credits on their tax returns. The cash payments aren’t included in gross income of the eligible taxpayers and aren’t deductible by the unrelated taxpayers. 

The final regs also include special rules related to excessive credit transfers and recapture events, including rules for determining whether an event has occurred, the resulting tax impact and the person responsible for that tax impact.  

The final regulations also provide rules for a mandatory IRS pre-filing registration process through an electronic portal. The pre-filing registration process needs to be completed, and a registration number received, before making an election to transfer eligible credits. In addition, the final regulations describe specific rules for partnerships and S corporations as eligible taxpayers and transferee taxpayers. 

The Inflation Reduction Act’s transferability provisions allow businesses to transfer all or part any of 11 clean energy credits to a third-party in exchange for tax-free immediate funds, so businesses can take advantage of tax incentives if they don’t have sufficient tax liability to fully utilize the credits themselves. Entities without sufficient tax liability were previously unable to realize the full value of credits, which raised costs and created challenges for financing projects.

The Inflation Reduction Act also allows tax-exempt and governmental entities to receive elective payments for 12 clean energy tax credits, including the major investment and production tax credits, along with tax credits for electric vehicles and charging stations. Businesses can also choose elective pay for a five-year period for three of those credits: the credits for advanced manufacturing (45X), carbon oxide sequestration (45Q), and clean hydrogen (45V).  Final rules on elective pay were issued in March.

To help taxpayers with transferring a clean energy credit or receiving a direct payment of an energy credit or CHIPS credit, the IRS built IRS Energy Credits Online (ECO) for taxpayers to complete the pre-file registration process and receive a registration number. The registration number needs to be included on the taxpayer’s annual return when making a transfer election or elective payment election for a clean energy credit. The registration process helps deter improper payments to fraudsters and gives the IRS basic information so any taxpayer that qualifies for these credit monetization mechanisms can access these benefits when filing a return and making an election.

Previously, the IRS issued proposed regulations for the transfer of applicable credits and temporary regulations for the mandatory IRS pre-filing registration process. For detailed instructions on how to use the tool, refer to Publication 5884, Inflation Reduction Act (IRA) and CHIPS Act of 2022 Pre-Filing Registration Tool. The IRS also updated the frequently asked questions based on the final regulations. More information can be found on the Inflation Reduction Act of 2022 page on IRS.gov.

As of April 19, over 900 entities have requested around 59,000 registration numbers for projects or facilities located across all 50 states plus territories. Approximately 97% of these projects are pursuing transferability.  A wide variety of credits are being used, but most of the transferability-related registrations are related to solar and wind projects using the investment or production tax credit. More than 1,300 projects or facilities submitted are pursuing the elective pay mechanism, including submissions from more than 75 state and local governments to register approximately 650 clean buses and vehicles through elective pay.   

The value of the tax credits for such projects isn’t determined during the pre-filing registration process but instead is determined after an entity files their tax return. 

The number of registration number requests so far does not include cases where an entity has not yet formally requested a registration number, including those who may have work saved in progress in IRS ECO. Registration numbers, which accelerate return processing and help prevent improper payments, are being issued on a rolling basis.  The IRS has already issued approximately 40,000 registration numbers.

Crux, a sustainable finance technology company that has been helping with transfers of clean energy tax credits, pointed out in an email that the final guidance largely affirms last June’s proposed transferability guidance. The proposed rules already clarified and supported tax credit transfer deals, which have seen significant growth in the market to an estimated $9 billion since June 2023. The Treasury declined to change some of the rules related to passive and active tax liabilities for individuals and S-corporations. The requirement that tax credits are sold in vertical, not horizontal, slices is also retained.

The IRS confirmed in the final regulations that there are no restrictions on the ability of project owners to obtain loans — either from a tax credit buyer or a third party lender — secured by a tax credit sale agreement. The IRS reiterated that companies must get a pre-filing registration number in order to complete a tax credit transfer. While more than 45,000 projects have already submitted pre-registration filings, some commenters noted specific challenges faced by smaller projects, so technology will be crucial in streamlining this process.

“While a multiyear market for transferable tax credits is already well underway, the final guidance released today gives further clarity on this key tool for financing clean energy and manufacturing here in the U.S.,” said Crux CEO Alfred Johnson in a statement. “With these final rules set, we expect to see the market continue to accelerate rapidly.”

Crux currently works with over 100 partners and has over $8 billion in transferable tax credits listed on its platform.

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Accounting

Continuous Auditing Transforms Corporate ERPs

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continuous auditing transforms corporate erps

As corporate accounting departments cross the threshold into late July 2026, the adoption of continuous, automated auditing systems has reached a definitive turning point. Driven by advances in artificial intelligence and deep integration with modern Enterprise Resource Planning (ERP) platforms, leading finance organizations are moving away from traditional, periodic post-hoc audits in favor of real-time, 100% transactional verification. This technological transition is redefining internal control environments, reducing compliance costs, and eliminating the structural delays inherent in legacy quarterly closing processes.

Unlike traditional auditing frameworks that rely on statistical sampling—a process that inevitably leaves operational blind spots—continuous auditing software monitors operational data feeds continuously. Every purchase order, electronic invoice, payroll disbursement, and cross-border wire transfer is automatically cross-referenced against established corporate governance parameters, regulatory tax schedules, and anti-fraud algorithms in real time. Anomalies or unauthorized ledger entries are flagged instantly, allowing internal audit teams to investigate and remediate compliance gaps immediately rather than months after the close of a financial period.

The implications for executive financial management are far-reaching. By embedding continuous verification directly into daily transaction workflows, chief financial officers gain uninterrupted visibility into the organization’s true financial standing. Real-time balance sheet auditing eliminates the severe operational bottlenecks associated with month-end and quarter-end financial reconciliations, freeing accounting professionals to focus on strategic financial modeling, tax planning, and capital allocation rather than manual data entry and spreadsheet consolidation.

However, implementing continuous auditing requires accounting leadership to invest heavily in data governance and technical upskilling. Internal audit teams must evolve from manual ledger reviewers into system architects capable of auditing complex algorithms and validating automated data pipelines. Accounting firms and corporate controllers that master continuous auditing will establish a resilient compliance framework capable of meeting stringent international regulatory standards with total transparency.

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Accounting

U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

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U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

WASHINGTON — In a major escalation of cross-border trade friction, U.S. President Donald Trump has signed executive orders imposing new 50% tariffs on a wide selection of Canadian exports, citing discriminatory practices by Ottawa targeting American auto, dairy, and beverage industries.

The new duties, announced Monday, will take effect in 30 days. They target a broad spectrum of consumer and industrial goods—ranging from wine, liquor, and milk products to commercial cement, furniture, clothing, and hockey equipment.

Untested Legal Mechanism

To enact the sweeping measures, the administration invoked Section 338 of the Tariff Act of 1930—a rarely used legal provision allowing the executive branch to levy additional tariffs of up to 50% on foreign nations deemed to discriminate against U.S. commerce.

White House officials noted that Section 338 addresses trade discrimination rather than national security or economic emergencies. The move comes months after prior global emergency tariffs faced legal challenges in domestic courts, signaling Washington’s pivot toward alternate statutory authorities to maintain import duties.

Senior administration officials briefed reporters that the measure directly responds to Canadian provincial bans on U.S. alcohol, restrictions on American vehicle exports, and import quota disparities affecting U.S. dairy and cheese producers relative to third-party trading partners.

“While the administration continues to secure reciprocal trade agreements globally, Canada retaliated against efforts to protect domestic industry,” U.S. Trade Representative Jamieson Greer stated.

USMCA Impact and Carve-Outs

Significantly, the newly ordered 50% duties will apply to designated items even if they otherwise comply with the United States-Mexico-Canada Agreement (USMCA).

However, the administration confirmed key targeted exemptions:

  • Energy products (including oil and natural gas)
  • Potash and critical minerals
  • Fish and seafood
  • Goods already governed by sector-specific duties (such as existing steel and aluminum tariffs)

Administration representatives emphasized that the tariffs do not stem from recent disputes concerning drifting Canadian wildfire smoke, noting that policy options regarding environmental spillover remain under separate review.

Canadian Response and Market Reaction

Following the White House announcement, the Canadian dollar experienced a sharp decline against the U.S. dollar, falling approximately 0.4% during evening trading.

Canadian Prime Minister Mark Carney issued a statement emphasizing that Canada’s earlier counter-duties had merely matched previous U.S. trade actions. “Canada stands ready to engage intensively to address outstanding issues with the U.S. to the mutual benefit of our citizens,” Carney stated, pointing to detailed proposals Ottawa submitted to modernize the USMCA framework.

Ontario Premier Doug Ford took a firmer stance, urging a “dollar-for-dollar” reciprocal response if the measures go into effect on August 19.

With a 30-day implementation window before the duties officially lock in, industry associations and trade groups on both sides of the border are calling for urgent bilateral negotiations to avert further supply chain disruption across North America.

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Accounting

Automated Continuous Auditing: Transforming Compliance and Real-Time Financial Oversight

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Transforming Compliance and Real-Time Financial Oversight

The traditional accounting paradigm—defined by periodic monthly closures and post-hoc annual audits—is rapidly giving way to continuous, automated financial oversight. As of July 2026, forward-thinking accounting practices and multinational corporate finance departments are leveraging continuous auditing systems powered by advanced machine learning models. These systems monitor operational transactions in real time, shifting audit methodologies from sample-based post-analysis to absolute, 100% transaction-level verification.

The operational advantages of continuous auditing are transformative. Standard auditing procedures historically relied on statistical sampling, which, despite rigorous methodology, inherently left gaps where anomalies or fraudulent transactions could go undetected for months. Modern continuous auditing platforms integrate directly with enterprise resource planning (ERP) databases, instantly cross-referencing purchase orders, invoices, bank feeds, and tax records. Any deviation from established control parameters or unusual transaction behavior triggers immediate flags for internal audit teams, dramatically reducing detection lag from quarters to seconds.

Beyond fraud prevention, continuous auditing fundamentally alters internal reporting and decision-making. Executive leadership no longer has to wait weeks after the close of a quarter to evaluate precise financial standing; real-time verified ledger data provides an uninterrupted view of operating margins, tax liabilities, and cash flow dynamics. This real-time visibility enables corporate controllers to adjust capital allocation strategies dynamically, mitigating liquidity constraints and capitalizing on emerging commercial opportunities far more efficiently than competitors bound to legacy reporting cycles.

However, implementing continuous auditing requires accounting professionals to acquire new analytical capabilities. The role of the auditor is evolving from manual data reconciliation toward system validation, algorithmic model governance, and strategic risk interpretation. Accounting firms and corporate finance departments must invest in continuous technical education, ensuring that audit staff possess the data engineering skills necessary to design, maintain, and evaluate complex automated compliance systems.

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