[RE-wrenches] IRS 25D

[Marco Mangelsdorf]

Just released yesterday.

https://www.irs.gov/newsroom/faqs-for-modification-of-sections-25c-25d-25e-30c-30d-45l-45w-and-179d-under-public-law-119-21-139-stat-72-july-4-2025-commonly-known-as-the-one-big-beautiful-bill-act-obbb
7. For purposes of the residential clean energy credit under section 25D,
can a credit be claimed for property installed after December 31, 2025, or
constructed after that date, if a taxpayer pays for the property on or
before December 31, 2025?

No. Section 25D(e)(8)(A) provides that an expenditure with respect to an
item is treated as made when the original installation of the item is
completed. If installation is completed after December 31, 2025, the
expenditure will be treated as made after December 31, 2025, which will
prevent the taxpayer from claiming the section 25D credit. In the case of
an expenditure made in connection with the construction or reconstruction
of a structure, section 25D(e)(8)(B) provides that such expenditure will be
treated as made when the original use of the constructed or reconstructed
structure by the taxpayer begins. If such construction or reconstruction is
completed and taxpayer’s original use of the structure begins after
December 31, 2025, the expenditure will be treated as made after December
31, 2025, which will prevent the taxpayer from claiming the section 25D
credit.
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