The U.S. has a long history of supporting energy infrastructure through the U.S. tax code. The investment tax credit (ITC) for solar and storage has supported private investment in manufacturing and project construction, a vital part of meeting our nation’s energy policy goals, lowering electricity bills, and driving job growth. The credits enacted or amended as part of the Inflation Reduction Act (IRA) in 2022 further incentivized the development of solar and storage projects that pay prevailing wages and employ apprentices; use domestically made steel and manufactured products; are located in geographic areas that previously relied on fossil fuel infrastructure and jobs; and are located in or serve low-income areas.
The IRA also added other policy innovations to the tax code, including reinstating solar’s eligibility for the production tax credit (PTC); allowing taxpayers to transfer clean energy credits; permitting certain entities like nonprofits and governments to receive cash instead of credits; providing credits for interconnection costs; and establishing new technology-neutral electricity production and manufacturing tax credits, including for solar and storage.
In 2025, the One, Big, Beautiful Bill Act (OBBBA) significantly tightened the timeline for solar projects. Under the new requirements, any solar project that begins construction after July 4, 2026, must be placed in service by December 31, 2027. The OBBBA left unchanged the phasedown for the energy storage ITC, which begins in 2034, and the manufacturing tax credit for solar and storage components, which begins in 2030.
The OBBBA also introduced complex Prohibited Foreign Entity (PFE) requirements. Taxpayers must comply with most of these rules beginning in 2026 for the ITC, PTC, and the manufacturing tax credit, though certain requirements apply beginning post-enactment of OBBBA.
To qualify, taxpayers are required to pass three PFE screening tests:
The ITC is one of the most important federal policy mechanisms to support the growth of solar and storage in the United States. Since the modern ITC was enacted in 2006, the U.S. solar industry has grown by more than 10,000 percent. In 2022, SEIA successfully advocated for the ITC and passage of the IRA, which has provided critical stability for businesses and investors. SEIA also played a key role in limiting the scope of proposed solar and storage ITC rollbacks under the OBBBA.
The Section 45X Advanced Manufacturing Production Credit is another critical federal incentive established under the IRA to promote the domestic manufacturing of clean energy components, including those used in solar and storage projects. Since the tax credit was enacted in 2022, the U.S. has risen from 14th to 3rd globally in solar panel manufacturing capacity. SEIA successfully advocated for this credit in the IRA and helped prevent proposed rollbacks under the OBBBA.
SEIA's Tax & Accounting Committee discusses pressing tax issues on Capitol Hill and in the Administration. The group is comprised of leading tax attorneys and consultants in the country as well as our member companies’ tax experts.
SEIA’s Tax & Accounting Committee discusses pressing tax issues on Capitol Hill and in the Administration. The group is composed of leading tax attorneys and consultants in the country as well as our member companies’ tax experts.
SEIA also has an Energy Credit Implementation Task Force, composed of SEIA Board members, that regularly meets to cover federal tax policy.
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