The IRS published Notice 2022-50 on October 10, 2022, calling for public comments on the elective payment and credit transfer provisions of the Inflation Reduction Act of 2022 (Public Law 117-169, 136 Stat. 2003 (August 16, 2022)) to be filed by November 4, 2022. Over 190 letters were filed in response. These letters contained specific comments and questions which will be available for use by the Treasury and IRS in anticipation of guidance on implementing § 6417 and § 6418.
Baker Botts has prepared this finding tool below that organizes the letters alphabetically by commenter name and lists the topics addressed in each letter. We reviewed each letter that was filed to develop our summary of the topics covered by that letter. Recognizing that browsing through the comments on Regulations.gov to find the letters of interest is very cumbersome, this is our contribution to facilitating development of the needed guidance on these new provisions. With this table, although you cannot do a word search through the text of all the letters, you can search for the letters we have indicated cover a topic of interest (for example, use Control + f to find all letters commenting on "recapture"). We hope you will find this tool useful.
Commenter Name |
Signed By |
Topic |
Comment Document |
26 Organizations |
Center for American Progress |
Identification; monitoring; general guidance |
|
ACP, ACORE, AEE, SEIA |
JC Sandberg |
General comments |
|
Advanced Energy Economy |
Nat Kreamer |
Eligible entities; tax-exempt entities; documentation; recapture; third-party ownership; partnership eligibility; S corporation eligibility |
|
Afloat, Inc. |
Afloat, Inc. |
Documentation |
|
Air Company |
Natalia Sharova |
Direct Pay timing; Procedures following 5-year Direct Pay period |
|
American Chemistry Council |
Kimberly Wise White |
General comments |
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