Additional ACORE Comments on Domestic Content

Seth Hanlon, Deputy Assistant Secretary
Department of the Treasury
1500 Pennsylvania Ave., NW, Room 3120
Washington, DC 20220

Re: Additional ACORE Comments in Response to Notice 2023-38

Dear Deputy Assistant Secretary Hanlon,

On behalf of the American Council on Renewable Energy (“ACORE”), I write to provide additional comments in response to Notice 2023-38 (“the Notice”) published by the Department of the Treasury (“Treasury”) and Internal Revenue Service (“IRS”) containing preliminary guidance on the domestic content bonus provision under the Inflation Reduction Act of 2022 (“IRA”). While the comments below reflect areas of needed clarification, ACORE commends Treasury for guidance that takes critical first steps to provide certainty to taxpayers, while so far reflecting many of the industry’s recommendations to facilitate a swift and sustained transition to domestic manufacturing.