Comments of the Electric Power Supply Association on the
Treasury Department and Internal Revenue Service
Request for Comments on Implementation of Public Law 117-169
(Notice 2022-49)
Venue: The Department of the Treasury and Internal Revenue Service
Reference: Notice 2022-49
Summary: EPSA filed in response to the Treasury/Internal Revenue Service Request for Comments on Certain Energy Generation Incentives regarding key provisions in the Inflation Reduction Act (IRA), specifically the IRA’s Addition of the Zero-Emission Nuclear Power Production Credit (§ 45U). EPSA recommend that Treasury/IRS sharpen and solidify guidance on the definition of gross receipts, take full account of programs providing governmental (out-of-market) support, and rely on a neutral, independent entity to certify § 45U credits for the purposes of payment reduction.