The Essentials

On 15 August 2025 the IRS released Notice 2025-42 (the Notice), which restricts the methods that developers of wind and solar projects can use to determine whether they have begun construction for purposes of the section 45Y production credit and the section 48E investment credit on and after 2 September 2025.

Under Secretary Doug Burgum, the Department of the Interior (DOI) has quickly moved to implement Sections 4 and 5 of President Trump’s 7 July Executive Order 14315 titled “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources.”

On 2 April 2025, President Trump announced a series of “reciprocal” tariffs on US imports from all countries.  The tariffs apply at different rates by country, starting at a baseline of 10% and reaching as high as 50%.