On April 25, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations with respect to the transfer of certain energy transition tax credits under Section 6418 (the Final Regulations).1 Despite receiving a significant number of comments (approximately 80 comment letters), the Final Regulations are generally consistent with the proposed regulations under Section 6418 released in June 2023 (the Proposed Regulations).
