Clean Energy
What tax credit compliance requirements apply to solar projects?
Solar projects claiming Section 48E, Section 45Y or the legacy credits face prevailing wage and apprenticeship (PWA), Foreign Entity of Concern (FEOC) / prohibited foreign entity (PFE), beginning of construction (BOC), domestic content and state requirements. For solar, timing carries particular weight.
Timing decides more for solar.
Under current rules, credit availability for solar facilities depends on when construction began or when the facility is placed in service. IRS guidance also limits the methods available to establish beginning of construction for most solar projects. The evidence behind your beginning of construction date needs to be documented as the work happens.
Empact organizes the physical work records, contracts and supporting evidence behind your beginning of construction position.
What Empact manages for solar
Beginning of Construction
Document physical work and continuous progress supporting the project's beginning of construction date.
Learn more about Beginning of ConstructionPrevailing Wage & Apprenticeship
Review wage and apprenticeship records during construction and prevailing wage records for alteration and repair work after placed in service.
Learn more about Prevailing Wage & ApprenticeshipFEOC / PFE
Review ownership, effective control and, where required, material assistance documentation for projects claiming Section 45Y or 48E.
Learn more about FEOC / PFEDomestic Content
Review steel or iron and manufactured product documentation behind domestic content bonus claims.
Learn more about Domestic Content
Frequently Asked Questions
Yes, subject to the current rules on beginning of construction and placed in service timing. Eligibility depends on when construction began, when the facility is placed in service and the project's facts.
IRS guidance sets the available methods, and for most solar projects those methods are narrower than in the past. The evidence needs to show physical work of a significant nature and continuous progress, documented as it occurs.
Projects claiming Section 45Y or 48E are subject to prohibited foreign entity restrictions, including material assistance rules for certain projects. Projects claiming the legacy Section 45 and 48 credits are not.
Know where your solar project's compliance stands.
Discuss your project's timeline, records and requirements with Empact.