ACORE Comments on Direct Pay and Transferability Regulations

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Office of Associate Chief Counsel
(Passthroughs & Special Industries)
Internal Revenue Service
1111 Constitution Ave, NW
Washington, DC 20224

Dear Office of Associate Chief Counsel,

The American Council on Renewable Energy (“ACORE”) respectfully submits these comments in response to the U.S. Department of the Treasury (“Treasury”) and Internal Revenue Service (“IRS”) request for public comment in response to the proposed regulations pursuant to REG-10607-23 and REG-10610-23 (“proposed regulations) implementing the direct pay and transferability provisions of the Inflation Reduction Act of 2022 (“IRA). ACORE is a 501(c)(3) national nonprofit organization that works to unite finance, policy and technology to lead the transition to a renewable energy economy