IRS opens Pre-filing Registration Tool for clean energy transferable tax credits

Today, the IRS launched the online IRA and CHIPS Pre-filing Registration Tool for clean energy projects (we’re calling it the “portal”). The portal can be used to pre-register eligible clean energy tax credits as required by the Inflation Reduction Act (IRA). The IRS also released a helpful user guide and tutorial video.

The opening of the portal is an important milestone for the continued growth of the market for transferable tax credits, which is on track to clear billions of dollars of tax credits in the first year of the program. Sellers of tax credits are now able to obtain pre-registration numbers for their credits, and, in turn, buyers are able to obtain certainty that the project meets initial requirements to register with the IRS — adding a valuable validation layer to the tax credit market.

A few takeaways regarding the portal announcement:

1. Companies should begin pre-filing as soon as practicable for credits they’re listing (or have sold) for 2023. The IRS recommends that companies complete the pre-filing registration process at least 120 days before their tax filing deadline.
2. As soon as practicable also means after a project has entered service. The IRS specifies that projects must be placed-in-service prior to completing the pre-filing registration. 
3. Registration numbers will be issued after the pre-filing registration review is completed. Following the review of the submission, the IRS will notify the applicant that the application is “returned” with or without comment (open or closed). If the application is returned open, or with comments, the applicant must address the comments before receiving a registration number. 

At Crux, we are keenly focused on streamlining the transaction process for buyers and sellers of clean energy tax credits and their advisors. Just as the launch of the Treasury pre-registration portal will kick off a new phase for the market, it will also kick off a new phase of our product development. 

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In the coming months, we will be incorporating new tools to help developers and buyers track and manage pre-registration, the tax filing process, and reporting. These tools will serve buyers, sellers, and our intermediary partners, reducing uncertainty and administrative burdens associated with managing the full lifecycle of tax credit transactions. 

We recently completed a broad survey of the market, which will be released in January 2024 (sign up for The Crux of It newsletter to receive it first!). The data indicated that one of the primary blockers for potential buyers to enter the market is uncertainty about regulatory guidance. The opening of the portal — alongside the significant volume of recent guidance — are important enablers for this market to continue to thrive in 2024.

The market increasingly calls for technology like Crux to provide structure and critical tools to manage transactions. Get in touch with us today to learn more about the portal launch, our latest insights on the market, and how to get early access to new features on Crux.