United States Reduce Act欧盟一直在研究适当的响应方法,提高欧盟作为绿色投资目的地的吸引力,不违反世贸组织规则或自身国家援助规则。
spanid=more-8449>/span>the EU Chips Act)!削弱国家援助规则建立欧盟紧急主权基金and mobilize WTO-compliant trade defense instruments. Other Member States have expressed concern that such an approach would risk undermining EU provisions on State Aid and fragmenting the EU internal market.With some justification, smaller EU Member States are concerned that weakening the EU's State Aid rules would favour more fiscally powerful Member States (52% of the Temporary Crisis Framework (TCF) established following Russia's invasion of Ukraine was notified by Germany and a further 24% by France). Such Member States would prefer the creation of a joint EU fund – a proposal in turn opposed by fiscally conservative Member States who reject any further joint EU borrowing.
On 1 February, the Commission released its Communication for A Green Deal Industrial Plan for the Net Zero Age (the Communication) which contains a series of proposals for discussion at the EU Council Summit on February 9-10. The differences between the various Member States noted above, are likely to influence the discussions at the Council Summit and impact the formal proposal which is expected to be presented to the European Council in late-March.
Contents of the EU's Proposal
The key elements of the Communication are:
- A Net-Zero Industry Act (NZIA)
- A Critical Raw Materials Act (CRMA);
- A temporary Crisis and Transition Framework (TCTF) State Aid framework;
- Repurposing existing EU programs to fund the green transition!and
- Production targets;
The NZIA is intended to create a simplified regulatory framework for production capacity. It will target key product sectors including batteries, wind-turbines, heat pumps as well as technologies including solar, electrolyzer and carbon capture and storage (CCUS). The list of targeted sectors suggests that the Commission intends building on existing initiatives such as the proposed Batteries and Waste Batteries Regulation and legislative proposals forming part of its Hydrogen Strategy.
The CRMA is intended to ensure access to critical raw materials by:
- diversifying sourcing;
- reducing dependence on highly concentrated supplies from third countries;
- improving recycling of materials already on the internal market!并 创建同心国的Critical原材料俱乐部,帮助确保安全、可持续和可支付的全球原材料供应。
- 简化提供国家援助进程实现工业进程去碳化; 提高援助赠款第三国项目;
- 为战略网-零值链中大型新生产项目提供额外援助
- revation绿色交易块免责规则,提高关键部门通知阈值,如氢和CCUSThe TCTF will be in place only until the end of 2025
The EU President has made clear she prefers the establishment of a common ‘European sovereignty fund' to incentivize continued green production in Europe, rather than run the risk of fragmenting the internal market and the creation of regional disparities by allowing wealthier EU Member States to leverage their own, stronger economies.
To achieve this (whilst avoiding the difficult issue of raising further debt) the Communication proposes repurposing existing EU programs and initiatives to fund the green transition:
- The REPowerEU initiative would be repurposed to provide additional grants and facilitate access to funding through national one-stop-shops for permitting renewables and net-zero-projects;
- Grants from the Brexit Adjustment Reserve would be re-directed to renewable projects!并 Investeu程序简化以鼓励私人投资优先部门。
这些提议是现有绿色筹资流之外的建议,包括
Conclusion
This is an important response from the EU. The initial proposal indicates significant repurposing of existing funding streams. If the proposal reaches Council in March more-or-less intact, there will be significant investment opportunities for European companies. There is time for the proposals to be adjusted before March, but companies wishing to do so will need to be swift and smart.
For the UK, this proposal may be problematic as it risks leaving the country between two major trading partners both of whom now have large green investment plans backed up by impressive funding.
Fostering improved, clean transportation has the potential to benefit the country enormously, and advances key goals of the Biden Administration. The transportation sector is the largest source of greenhouse gas emissions in the United States, accounting for one-third of all emissions, and must be addressed for there to be any hope of meeting climate goals. Transportation also affects every American's day-to-day life, from how they participate in their communities to how they pursue economic opportunity and empowerment, representing a significant opportunity to promote equitable growth.
The Blueprint is the Administration's most fleshed out vision for pursuing these goals. The Blueprint outlines a comprehensive approach, addressing changes to every mode of transportation, and proposing to do so through virtually every policy lever available—a true "whole of government" approach. It is consistent with, and further advances, key themes in the President's climate policy enunciated from day one, and further reflected in his signature legislative accomplishments, the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA).
The Blueprint was a highlight of government speakers at the recent Government/Industry Conference for the auto industry, sponsored by the Society of Automotive Engineers: In a keynote, Gabe Klein, Executive Director of the newly formed DOE-DOT Joint Office of Energy & Transportation, called it the "most important policy document in a decade."
Below are some of the key features:
- Multiple technological solutions will be needed, reflecting an evolving decarbonization path for several sectors. To many, the electric passenger car is the symbol of transportation decarbonization. But power demands and weight considerations, among other issues, may make it more difficult to use this technology in other sectors, including on-highway freight, maritime, and aviation. The Blueprint recognizes that additional technology must be deployed, including those not yet fully commercialized. It focuses on three: battery electric, hydrogen fuel cell, and sustainable biofuel.
The continued prominence of liquid fuels in a transportation decarbonization plan is especially notable. There remains active debate, even within the agencies which authored the Blueprint as to whether the types of "sustainable" fuels being promoted have the full range of climate benefits they claim.
- But new technology is not the only tool. In addition to developing and deploying clean technology, the Blueprint will promote measures to decrease transportation demand and increase transportation efficiency. The Blueprint seeks to redesign the communities in which we live, so that people are physically closer to where they work, learn, and recreate. Consistent with the Biden Administration's "whole of government" approach, this will involve policymakers outside of the four agencies who authored the report, including non-federal entities like towns, cities, and counties with jurisdiction over zoning laws that shape land use. The Blueprint also stresses policies to encourage the most climate-friendly mode of transportation when movement is necessary: For movement of people, this will likely result in renewed focus on mass transit and emission-free micromobility options.
- A three stage timeline with interim targets. Broadly speaking, between now and 2030, the Blueprint focuses most on research and investments to support deployment.In the 2030s, the focus is on scaling up clean transportation solutions, and the 2040s will be about completing the transition to a net zero transportation sector. But there are plenty of interim benchmarks in between, such as a commitment that all new light-duty acquisitions for the federal fleet be zero emission by 2027, and 30% of private sales of medium and heavy duty vehicles be zero emission by 2030.
- Continued focus on equity. Ensuring a just transition of the transportation sector is a cornerstone of the Blueprint. Among other concerns, this will mean a focus on ensuring that zero emissions technology successfully penetrates all communities. This could mean creating enhanced subsidies for acquiring electric vehicles, ensuring charging stations are meaningfully available in historically overburdened neighborhoods, and ensuring that transit service is fully accessible for the differently abled.
- Interaction with advanced driver assistance technology (ADAS). The Blueprint acknowledges that transportation will "dramatically change" in "ways that are hard to forecast," focusing in particular on another transformational shift occurring in the transportation sector: the emergence of automation and connectivity, up to full vehicle automation. Although such technology is often discussed for its appealing safety benefits, it may also reduce congestion and result in significant environmental gains as well.
- The continued role of agency-promulgated regulatory standards. The Blueprint is clear that agency-promulgated, technology-forcing regulation has an important role to play in decarbonizing transport, even if the BIL and IRA focused mainly on incentive-based mechanisms. The Blueprint specifically mentions renewable fuel standards, and emissions standards for heavy duty on-highway, off road, and fuel pipeline transportation. More are likely in store, although the Biden Administration will have to tread carefully in light of recent Supreme Court precedent narrowly interpreting the agency enabling statutes that will serve as the authority for these rules.
Whether the Blueprint's lofty ambitions will be met remains to be seen, but the document is an important outline of the federal agenda to come, at least for the remainder of Biden's presidency. The transportation sector is in the process of fundamental change, set to dramatically reduce where feasible uses of the internal combustion engine—the technology that served as its bedrock for over 100 years. This process will create exciting opportunities and difficult choices, and the Blueprint provides important insight into federal priorities that should be thoroughly understood when engaging policymakers going forward and when making investment decisions.
Notice 2023-9, "Section 45W Commercial Clean Vehicles and Incremental Cost for 2023"
Concurrent with the white paper and Notice 2023-1, discussed in a separate blog, on December 29, 2022, the IRS released Notice 2023-9, which provides a safe harbor for determining the incremental cost of qualified commercial clean vehicles for the section 45W credit.
The amount of the commercial clean vehicle credit under section 45W is the lesser of (1) 30 percent of the taxpayer's basis in a vehicle if the vehicle is not powered by a gasoline or diesel internal combustion engine (or else 15 percent) or (2) the incremental cost of the vehicle.第45W节信用额上限为7 500美元(车辆总重量级小于14 000磅的车辆)或40 000美元(车辆总重量级小于14 000磅或以上的车辆)。
GVWR小于14 000磅的所有其他街车,纳税人可使用7 500美元增支成本
Continue Reading…
Notice 2023-1 which provides proposed definitions of certain terms relevant for the section 30D credit.
White Paper on "Anticipated Direction of Forthcoming Proposed Guidance on Critical Mineral and Battery Component Value Calculations for the New Clean Vehicle Credit"
As described in more detail below, to determine if a vehicle satisfies the critical mineral and battery component requirements, one must determine (1) if a threshold percentage of the value of the critical minerals in a vehicle's battery is extracted or processed in the United States or "free trade agreement" partner countries or recycled in North America and (2) if a threshold percentage of the value of the vehicle's battery components is manufactured or assembled in North America.
Generally, to determine the value of critical minerals and battery components, the white paper provides that manufacturers must use the arm's length price that was paid or would be paid by an unrelated purchaser using the transfer pricing principles of Internal Revenue Code Section 482.为了确定临界矿产品值,制造商可选择关键矿产品最终处理或回收步骤前后的任何日期,但该日期必须应用到电池内所有材料上。判定电池组件值时,制造商可选择电池组件最终制造或组装步骤前后的任何日期,但日期必须应用到电池内所有电池组件中万博体育app手机登录For each of the critical minerals and the battery component percentage calculations, the manufacturer may average the percentage calculations over a period of time with respect to vehicles from the same model line, plant, class, or some combination thereof for vehicles, the final assembly of which occurs in North America.
Critical Minerals Requirement
The section 30D credit requires that, for any EV placed in service in 2023 (after the publication of proposed guidance expected in March 2023), 40 percent of the value of the critical minerals in the EV's battery must be either extracted or processed in the United States or in any country with which the United States has a free trade agreement (FTA) in effect, or recycled in North America.万博体育app手机登录2024年增加50%,2025年增加60%,2026年增加70%,2026年后增加80%。
白皮书与第30D节相关介绍以下两大类采购链: Free Trade Agreement Guidance The FTA requirement has drawn substantial criticism from some European and Asian trading partners with significant EV manufacturing operations as being an unreasonable restriction on trade.U.S.万博体育app手机登录domestic manufacturers have also expressed general concerns regarding the availability of adequate supply of critical minerals from FTA partners. Yielding to those concerns, the white paper notes that the term "free trade agreement" is not defined in the Inflation Reduction Act. Accordingly, Treasury and the IRS expect to seek comment in the proposed guidance on what criteria should be used to identify free trade agreements for purposes of the critical mineral requirement. Proposed criteria may include whether an agreement reduces or eliminates trade barriers on a preferential basis, commits the parties to refrain from imposing new trade barriers, establishes high-standard disciplines in key areas affecting trade (such as core labor and environmental protections), and/or reduces or eliminates restrictions on exports or commits the parties to refrain from imposing such restrictions, including for the critical minerals contained in electric vehicle batteries. Application of these or other criteria may broaden the universe of countries available to source critical minerals beyond the list of 20 countries with which the United States currently has a comprehensive trade agreement. Battery Components Requirement The section 30D credit requires that 50 percent of the value of an EV's battery components must be manufactured or assembled in North America if the EV is placed in service in 2023 (after the publication of proposed guidance expected in March 2023).万博体育app手机登录This amount increases to 60% in 2024 and 2025, 70% in 2026, 80% in 2027, 90% in 2028, and 100% after 2028. It is anticipated that proposed guidance will provide the following four steps for certifying that an EV meets the battery component requirement: The white paper also provides preliminary sketches of the following terms, although Treasury indicates it will supply more through proposed definitions of these terms in later guidance: Treasury clarifies that the constituent materials of battery components would not themselves constitute battery components (specifically, because constituent materials are produced by processing or recycling critical minerals, rather than through manufacturing or assembly).Importantly, because the incremental value of a battery component is determined by reducing the value of such battery component only by the value of other battery components contained in such battery component, this means that "the incremental value of battery components would include [i.e., would not be reduced by] the value of constituent materials contained therein." In the percentages calculation, this approach will have the effect of assigning significant weight to the location where constituent materials are first manufactured or assembled into a battery component—thus incentivizing industry participants to locate those activities in North America. And there will be the greatest "bang-for-the-buck" for locating in North America the manufacturing or assembly of the battery components with the greatest combined value of constituent materials plus manufacturing value-add. Notice 2023-1, "Certain Definitions of Terms in Section 30D Clean Vehicle Credit" For the section 30D clean vehicle credit, the final assembly of a vehicle must occur within North America, and a manufacturer's suggested retail price cannot exceed the applicable limitation, which depends on vehicle classifications.货车、运动公用车和小卡车的适用限值为80 000元MSRP,任何其他车辆的适用限值为55,000元MSRP万博体育app手机登录The notice provides the following new definitions to clarify key terms that appear throughout section 30D. Final Assembly Section 30D(d)(5) defines "final assembly" as "the process by which a manufacturer produces a new clean vehicle at, or through the use of, a plant, factory, or other place from which the vehicle is delivered to a dealer or importer with all component parts necessary for the mechanical operation of the vehicle included with the vehicle, whether or not the component parts are permanently installed in or on the vehicle." The notice provides the following additional guidance, explaining that a taxpayer may rely on either of the indicators below to determine a vehicle's location of final assembly:
1232fll和 (B) 制造商建议每件附属件或可选设备在向经销商交付时实际附属于该汽车的零售交付价,该价不在根据15U.S.C.所述这类汽车价格内1232/f)(1),见15 U.S.C.1232/f)(2).通知解释称,如15 U.S.C.描述的那样,该信息贴在车挡风玻璃或侧窗标签上1232. 第30D(f)(11)(c)节后通知称车辆的“车辆分类”必须符合40CFR600.002中为货车、运动工具车和小卡车提供的规则和定义。
On August 16, 2022, President Biden signed the Inflation Reduction Act (IRA) into law, directing a record $370 billion toward clean energy investments.
Yesterday, the White House released a 182-page guidebook to the IRA entitled Building a Clean Economy. John Podesta, Senior Advisor to the President for Clean Energy Innovation and Implementation, explains in his introduction that the guidebook "provides a program-by-program overview of the Inflation Reduction Act, including who is eligible to apply for funding and for what purposes." In the coming weeks and months, the Administration will provide further updates on www.CleanEnergy.gov.
See here for our post providing an overview of the major energy provisions in the IRA.
(a) The make, model, model year, and any other appropriate identifiers of the motor vehicle;
(b) Certification that the motor vehicle is made by a qualified manufacturer, within the meaning of Section 30D(d)(3);
(c) Certification that the motor vehicle is treated as a motor vehicle for purposes of title II of the Clean Air Act;
(d) The gross vehicle weight rating of the motor vehicle;
(e) The battery capacity of the motor vehicle;
(f) The motor vehicle's vehicle identification number!and
(g) Such other information as the Secretary may provide on irs.gov.
With respect to the Section 30D credit, the following additional information needs to be provided:
(a) Certification that the motor vehicle is propelled to a significant extent by an electric motor that draws electricity from a battery that has a capacity of not less than 7 kilowatt hours and the battery is capable of being recharged from an external source of electricity, or the motor vehicle is a new qualified fuel cell motor vehicle;
(b) Certification that the motor vehicle is manufactured primarily for use on public streets, roads and highways (not including a vehicle operated exclusively on a rail or rails) and has at least four wheels;
(c) Certification that the final assembly of the motor vehicle occurred within North America;
(d) Certification of the percentage of the value of the applicable critical minerals contained in the electric vehicle's battery that were (i) extracted or processed in the United States or a FTA partner country, or (ii) recycled in North America;
(e) Certification of the percentage of the value of the EV battery components that were manufactured or assembled in North America;
(f) Whether the motor vehicle is a van, sport utility vehicle, pickup truck, or other vehicle!and
(g) The motor vehicle's manufacturer's suggested retail price.
Similarly, with respect to Section 25E and 45W credits, the manufacturer must provide additional information to show that vehicles satisfy the statutory qualifications for credit eligibility.
A vehicle seller, such as a dealer, must furnish a report to a purchaser not later than the purchase date and an annual report to the IRS, including the following information:
(a) The name and taxpayer identification number of the seller;
(b) The name and taxpayer identification number of the purchaser;
(c) The vehicle identification number, if assigned, of the vehicle;
(d) The battery capacity of the vehicle;
(e) For new clean vehicles, verification that original use of the vehicle commences with the purchaser;
(f) The date of sale, sale price of the vehicle, and maximum credit allowable to the purchaser!and
(g) If a purchaser makes an election to transfer the credit to the selling dealer that satisfies certain requirements for sales after December 31, 2023, any amount paid or allowable as a partial payment or down payment.
This revenue procedure notably does not require qualified manufacturers to certify as to a vehicle's satisfaction of the requirements in Section 30D(d)(7)—that the critical minerals in the battery have not been extracted, processed, or recycled by a "foreign entity of concern" and that the components contained in the battery have not been manufactured or assembled by a foreign entity of concern. This would seem to impose less of a diligence burden on manufacturers.同理,税收程序没有解决车辆购买者如何确定车辆满足这些需求的问题。我们注意到,IRS可添加这项附加认证要求,作为2024或2025前“秘书可能提供的其他信息”的一部分,而2024或2025前外国受关注实体规则生效。
IT似乎报告需要解决车辆信用分数问题万博体育app手机登录As such, two vehicles of the identical make, model, and year may not always have the same credit eligibility, which will vary depending on the composition of critical minerals and components and the location of final assembly.
Manufacturers and sellers must submit a declaration under penalties of perjury that the facts presented in support of this certification are true, correct, and complete. A purchaser of a vehicle can rely on the manufacturer's certification for the Section 30D, 45W, and 25E credits.
This revenue procedure does not provide any guidance on how to determine the value of critical minerals and components. The revenue procedure expressly notes that it does not constitute the guidance the IRS is required to propose regarding Section 30D(e)(1) (Critical Minerals Requirement) and Section 30D(e)(2) (Battery Components). Such guidance is due to be published separately, by no later than December 31, 2022.
最后,我们注意到税收程序没有表示政府会放松信用计划的法定时限-例如提供过渡期-正如许多制造商所请求的那样。
我们将继续监测和报告这些动态。
框架报告预览,其中得出结论说,世界当前轨迹到本世纪末都面临
2.5至2.9摄氏度变暖,并伴之以国际能源机构2022年世界能源展望的新的
报告,报告总结说,从现在
到2030年,世界每年至少需要花4万亿美元解决气候变化问题。 和这个挑战性背景抗衡,COP27决非直截了当。但这些'br'difficulties加之发展中国家和发达国家对>br>优先级的划分时间划分在会议前后紧张状态中最清晰显示
加速减缓气候的承诺,响应关于地球快速变暖对
影响的可怕科学警告具体地说,呼吁逐步减少所有
fossil燃料的努力最终在峰会最终协议中败出并突出显示全球排减承诺速度与避免最具破坏性气候影响需要的
步调之差。
COP27-A recap
COP21NDC汇总后将保持世界轨迹以避免
worst气候变化影响,并每5年审查一次enview
周期作用鼠标,迫使每个国家带更多'br>雄心勃勃NCDs返回COP2020年因Covid而错过了COP26,格拉斯哥市去年COP26成为第一个五年审查点,评估通过
Paris协议后排减进度Glasgow大会因美国之故也很重要环球气候问题重新投入世界舞台, 由
政府间气候变化问题专门委员会发布的权威科学评估, 列出了smission轨迹日益可怕的冲击,清楚地表明这是世界降低排放以避免灾难性全球变暖目标的决定性十年。
承诺,去年COP的结尾令主席眼泪近增,因为NDCs综合'br>勉强保住巴黎科学目标
1.5摄氏度高于工业前水平立方公尺比1.5目标/br/Celsius目标提高十分之九对地球产生灾难性天气影响,但为更好地实现
目标而达成的关键协议证明难以实现。
UNFCCC评估说,各国在实现1.5度/br/celius目标方面没有取得足够的进展,并请求所有成员国返回COP27并改进目标COP27的Br>焦点因此放在前协议的“执行”上-由Br>会议标题Captement of“Togates for 实现”-不期望主要新Climate
变换文本会商谈近195国努力使用COP27来点火,但只有29个有改进NDCsssss.s/p>
squatedUnited United Nations/CEP27上的国家代表团外,还有近2千个官方观察组织-共约33 500名代表。 ibr>At开源开源开源开源开源开源开源开源开源开源并解决深度公平问题, 由谁来承担气候干扰和经济发展收益的冲击和负负在今年
ss观察欧洲和中国异常干旱时,承认这种不平等和附属于解决的发展中世界的
意义,除埃及作为
主机的作用外,COP27被计为“AfricanCOP”。
历史学上,全球应对气候变化可大致归为
或减排或改适应(准备未来变换
气候变换-例如加固海墙或改善对关键
国家基础设施的保护)。COP添加了另一个官方类别-“损耗和损耗”-它“br”处理气候变化影响问题,侧重于当前气候变化经济不良效应,以及一国无法通过恢复能力努力恢复
的问题。
并在未来更贵处理COP27自巴厘G20会议归来试探新生活和希望,最后48
小时关键商谈因美国实际缺席而进一步受阻气候特使John
Kerry-一位关键交易人和有经验的谈判者-他与Covid>br/帮助脆弱国家应对气候
change-和Johnkerry支持计划的最后一分钟欧盟主动表示不包含法律责任
-是解锁协议的关键小岛屿国家联盟是会谈中的谈判阵营,称基金为“全世界的胜利”。
然而,关键细节说明基金将如何运作,包括支付者、数额和操作方式,留待未来会谈解决这一点很重要,因为它可能`Br>政治挑战美国请求国会为损耗和损耗基金追加气候拨款, 并可能出现挑战性问题,并面临创纪录通胀和由
俄罗斯入侵乌克兰引发的大规模生活成本危机有关其他Br>key发射者-最突出的是中国-为这样一个基金提供捐款的作用问题仍然有待解答。
not everyones's Happy..
虽然发展中国家实现了建立损耗基金的长期目标,但
COP27未能实现迫使国家改善NDCs的目标The negotiations also
failed to secure an agreement to start a phase-out of all fossil fuels—language which at one
point had seemed to have made its way into the text, only to be withdrawn and replaced by the
Glasgow language of "phasing down" coal and "phasing out inefficient fossil fuel subsidies" after
objections from Saudi Arabia, Iran, and Russia.
Although an attempt to remove the 1.5 degree Celsius goal from the Declaration in favor of the
Paris Agreement's upper limit of 2 degrees failed, there was no mention of the requirement for
global emissions to peak by 2025, which scientists see as critical if the world is to meet the 1.5
degree Celsius target.减少排放焦点似乎因埃及增加低排放能源呼声
最后插入而削弱(俄罗斯入侵
Ukrain 和随后对俄罗斯油气公司的制裁触发非俄毒气的
点头)。
EU和UK表示失望,因为最终结果没有改善COP26上所作的
减排承诺委副会长表示, 国家有“下降短路 ” 补充道 : “我们应该多做多做多做多做多.我们Br失望我们没有实现这一点。 ”英国的 Alok
Sharma-CEP26主席表示,这一失望得到响应,他注意到省略逐步停用化石
燃料的承诺和任何语言都要求到2025年排放量封顶增强科学理解天然气生产中甲烷泄漏对
短期气候的影响以及比纯可再生能源游戏高排放轨迹概念加深了关于天然气过渡作用的辩论和争议Sharma总结说'br','我在Glasgow表示脉冲为1.5度微弱可惜它仍然保留在生命'br>支持上's/p>
butititn't all badNews..
除创建新的损耗基金外,CP27
中的其他亮点包括:
Celsius目标至关重要,因为它们是世界上两个最大排放者,并共同负责
全球排放量的50%; a交易214公司和政府承诺淘汰柴油和油车
2040; a200亿美元印尼能源过渡计划,以落实为
南非在COP26上创建的计划; Reference公告减少油气
操作的甲烷排放,开发绿色运输挑战,拓展Pirst Moler联运
区块并启动新的全球碳信用交易创举以加速发展中国家投资
能源转换和 协议中某些细节的巴黎协议处理
国际碳交易市场问题。
来自COP27的另一个亮点是多场边事件的广泛讨论,包括深入评估
对粮食和农业的影响和各种机会。
COP27还反映企业和民间社会作用在
COP进程的持续制度化COPs不再是单纯的联合国谈判,而只是定期
全球会议的一部分,由关注并受全球气候挑战影响者组成squmel>br>Sheik继续提升全球气候问题,并集中媒体和公关关注这一挑战-埃及有3000多媒体br>代表反映这一点。
阐明了这些计划的透明度和一致性原则并支持国际
净零排放计划核算和报告新标准,由国际>br>Stards组织发布,新努力还侧重于自愿碳>br市场排减的完整性关键元素包括基于科学的
目标需要进取短期排减量并重新呼唤企业和行业协会的气候倡导立场一致性
公司可以期望强化审查净零计划,基于这些
清除标准和期望。
归根结底,美国重新参战上个年度气候变化问题论坛由拜登总统(内阁秘书大全)和SqlmelSheik国会代表团组成,以突出美国投资解决Climate
change-历史记录(Investment
Rectection或IRA),帮助帮助美国运行自己的
NDC承诺并突出清洁能源和先进技术经济
契机。
Comment
>微弱最后文本引导多位推理家得出结论说,将气候变化限制为1.5摄氏度可能不再有
现实性:鉴于今年干旱和洪涝对世界多处造成的损害,这些损害已经影响到
世界多处,仅摄氏1.1摄氏度,这是一个暗淡的未来。But, since COP is the best we have
by way of a global system for managing climate change, it is a process that will have to be
made to work.
One other important lesson which should be taken away from the heated debate over differing
priorities at COP27 is the difficulty in neatly categorizing and separating "implementation" from
the issues of emissions reduction, global ambition, equity, integrity, and transparency that
underlie a solution to addressing climate change.
In terms of what we should expect from next year's COP28, there will be a focus on how to
operationalize the loss and damage fund, as well as a continued focus on the Global Goal on
Adaptation, the New Collective Quantified Goal on climate finance, and perhaps most important
for continued mitigation, the first Global Stocktake assessing progress on the NDCs of individual
countries and the on-going role of private sector emissions reduction commitments.
But achieving these tangible outcomes will require a sustained effort to rebuild trust and
confidence between the Global North and Global South.
2022年10月5日,国库局和国税局发布通知,请求对《降低通货膨胀法》('IRA')中能源税益的不同方面发表评论11月4日星期五前应提交所有评论,或电子发布www.reducts.gov或寄送国税局万博体育app手机登录日期过后提交的书面评语将予考虑,只要不延迟发布指南。
通知征求一般性意见,但也侧重于具体定义问题和业务问题除其他外,请求出自爱尔兰共和军新的国内生产和采购需求,包括采购关键矿产品以制造电动车辆和用美国生产的材料搭建某些合格设施需求新的双级信用结构中也产生请求,对于其中许多信用,纳税人如果满足某些工资和学徒需求,有资格获得更高信用(通常是基数的五倍)。万博体育app手机登录一份通知侧重于某些信用项新的直接支付或可转移性特征,这基本上导致向纳税人支付现金,而不管他们在申请信用的年份是否负税。
IRA为国库向纳税人提供指导设定极短的最后期限结果是,如通知中所述,利害相关方有有限时间权衡今日发布通知请求在11月截止时间前提交评语,既包括年末到期的受管制入计量(如EV税抵免),也包括后年到期受管制入计量(如ITCPTC技术中和PTC)。除征求一般性意见外,每份通知都提出一些具体问题,下文摘要中强调其中一小部分问题。
/lqliququq3MD4NDLCJ1cwiOiJOdhuczovL3d5cnMvcre万博体育app手机登录Notice 2022-46 asks stakeholders to answer a number of specific questions related to:- What factors and definitions should be considered to determine the place of extraction or processing of critical minerals and the value of those minerals;
- How the guidance should define the components of a battery and determine the place of manufacture or assembly of battery components and the value of those components;
- Whether guidance is needed to clarify the definition of "foreign entity of concern" and to the extent available, whether there is any existing regulatory or guidance frameworks for tracking whether manufactures are in compliance with the foreign entity of concern rules!万博体育app手机登录and
- Whether guidance is needed on the definition of "acquired," "use," and "lease."
- Notice 2022-47 requests comments on energy security tax credits for manufacturing under § 48C and 45X.通知2022-47请利害相关方评论:
Where需要进一步澄清第45X(c)节中“合格组件”定义; 应如何确定“整合、集成或集成”短语,当合格组件整合、集成或集成为另一个组件时; 财政部和IRS在判定合格先进能源项目信用评分选择标准时应考虑什么i/li+li+li+i+i+i+i+i+i+i+i+i+i+i+2+2+2+2+2+#li+++++++++++++++++++++++++++++++++++++++++2+2+2+2+2+2++2+2+2+2++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++2+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++万博体育app手机登录通知2022-48提出了多项定义问题,包括:政府在制定指南时应考虑哪些标准和技术用于确定节能商业大楼的“用能强度”。万博体育app手机登录i>li+li+i+i+i+i+i+i+i+i+万博体育app手机登录政府在通知2022-49中寻求的部分评论包括: 政府在制定指南和确定纳税人的信用资格时应考虑哪些行业标准;投资信用设施要求投资税抵免必须满足生产税抵免的所有要求,例如要求将发电出售给无关者;政府需要定义指南和政府确定术语时应考虑哪些条件(例如技术类型),如“无关人员”、“结构”和“毛收入!万博体育app手机登录i>/li+li+li+i+i+i+i+i+i+i+i+i+i万博体育app手机登录Notice 2022-50 requests comments from taxpayers on a number of questions, including: - Whether any guidance is needed on the terms used in these monetization sections, such as "applicable credit," "excessive payments," and "applicable entity";
- What potential issues and factors that the government should consider when a partnership or an S corporation makes such an election;
- What types of structures may be entered into by applicable entities and taxpayers that have elected to be treated as applicable entities;
- Whether any documentation or registration should be required and what factors the government should consider to prevent improper payments or excessive payments and whether clarification is needed on the penalty provisions for excess payments!CHIPS/LILQLIJJJJJJJJlGLU2JJJJJUJUNJUNQ3MD4EILCJIOIJOJJOJJOJJOJJOJOJOJL3D5cnMU3B2L3BJI9PNJJCLSSLVLVLVLVLIJJJJJJJJJJJUJJJBLGLULXLXLIJJJJJJJJJUJLUGLXUNQNQQQMDUNQ3MCDEILCILCJJJICUIOIJOJOJOJL3DL3DL2L2LLLLLICI通知2022-51具体请求评论,包括:
文献或证明应用来证明遵守奖金信用要求的情况以及信息方目前维护并可能创建的信息量;国库司和IRS应一致使用48C.F.R下提供的定义万博体育app手机登录§661对内容需求以及现有规范或指导,如FederalCrap Regional和BuildingAmerica BuyCA指导,可能有益于开发指导; 定义,如“合格设施组件”、“制造产品”、“终端产品”和“总成本”需要澄清国内内容需求万博体育app手机登录和/lili>处理制造产品子组件需要澄清。 squal='wp-blest-separator has-alpha-chane-o2023年2月12日清洁氢生产税抵免 第45V节 2023年8月16日技术中立PTC和ITC(第45Y和48E段)2025年1月1日前完成
In a series of prior blog posts, we previously highlighted the historic implications of the Inflation Reduction Act (IRA) for the U.S.'s international climate commitments, as well as for private companies navigating the energy transition. Shortly after our series published, the Senate passed the IRA on Sunday August 7th with only minor modifications to the bill's $369 billion in climate and clean energy spending. Today, the House passed the IRA without any further changes, and soon hereafter President Biden is expected to sign it into law.
However, this is only the beginning of the road!IRA四角将产生广度效果。 未来数月和数年中,我们期望看到对机构规则的强力操纵将决定IRA实施,并判定它作为能源策略的最终成功
As an initial matter, it seems Congress has not finished its work revamping the nation's climate and energy laws. As part of his agreement to support the IRA, Senator Joe Manchin (D-WV) announced that "President Biden, Leader Schumer and Speaker Pelosi have committed to advancing a suite of commonsense permitting reforms this fall that will ensure all energy infrastructure, from transmission to pipelines and export facilities, can be efficiently and responsibly built to deliver energy safely around the country and to our allies." While the exact contours of this legislation are not currently known, Senator Manchin's office recently released a legislative framework, which includes proposals to, among other things:
- tighten environmental reviews under the National Environmental Policy Act (NEPA);
- clarify the permitting and regulatory authorities of the Department of Energy and the Federal Energy Regulatory Commission;
- reform Clean Water Act provisions that allow state and local governments to impose additional requirements on federal permits!and
- create a list of strategically important energy projects, that the President can designate and periodically update, for streamlined permitting reviews.
According to Senator Manchin's office, permitting reform will receive a vote before the end of the fiscal year on September 30, 2022. Unlike the Inflation Reduction Act, which passed through arcane rules of reconciliation—and thus required only a simple majority—permitting reform will be subject to the Senate filibuster and require the support of at least 60 senators (and bipartisan agreement) to become law. At the moment, it is unclear whether broad bipartisan support exists for this measure!some Republicans have publicly signaled skepticism, and environmental activists have long opposed expedited fossil fuel permitting.However, in the past Republican Senators have expressed an interest in speeding the nation's permitting system. During this Congress, a bipartisan group of Senators introduced a law to accelerate infrastructure permitting, and all Republicans and Senator Manchin supported a resolution to disapprove of recent revisions to NEPA. Together, these actions suggest there may be some interest within the Republican caucus in implementing meaningful changes to current law, partisan divisions notwithstanding.
II.万博体育app手机登录减通货膨胀法关键赋值指南 外加,IRA本身有几部分未来数月将通过行政引导和规则制定过程予以澄清和实施守法标准支付工资、学徒和家用内容要求并计算温室气体排放法新税抵免 。
ahrfss/www.insideEnergyandense.com/2022/07/enger-support-for-电机-车-车-车-门-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电链/>这些规定并不适用于商业电车信用分量 。 具体地说,法律要求电电池组件的一定比例为“制造或组装北美 ”, 并适用百分比逐年变化 。 法律还要求电池中关键矿产品中一定比例为“提取或处理 ”, 在美国或与美国相邻的任何国家中实现“提取或处理 ” 。IRA § 13401(e).鉴于电车供应链的现状,预计许多汽车制造商难以满足这些外包需求万博体育app手机登录
However, key features of these clean vehicle credits have yet to take shape. By the end of this year, the IRA requires the Treasury Department to issue regulatory guidance to help shape and administer the battery and mineral sourcing requirements. Id. Among the questions open for interpretation are acceptable methods for calculating the "percentage of the value" for critical mineral and battery components, as well as better defining the terms "manufacture or assembly" and "extraction or processing." How Treasury addresses these points will have significant ramifications for the short- and medium- term value of the clean vehicle credits.
A much broader set of IRA tax credits seek to promote investment in, and use of, clean electricity, but their value depends on the interpretation of key labor and domestic content requirements. As currently structured, the IRA extends and modifies the Investment Tax Credit and Production Tax Credits that apply to certain renewable sources of power through the end of 2024. Id. §§ 13101, 13102. Beginning in 2025, similar projects will also be eligible for a new technology-neutral Clean Electricity Production Credit and a Clean Electricity Investment Credit, which apply to any domestically produced electricity source with a greenhouse gas emissions rate of zero. Id. §§ 13701, 13702. These credits, and others throughout the IRA, are keyed to the satisfaction of prevailing wage and apprenticeship requirements.
Specifically, if these wage and apprenticeship requirements are not satisfied the credits are worth five times less than they otherwise would be. Additionally, the IRA creates a 10% "domestic content bonus" when facilities certify that certain percentages of steel, iron, and other manufactured products used in the facility are made in America, and further increases the value of the credit for projects located in "energy communities," i.e.棕田网站或经济困境前化石燃料生产网站解释应用将极大影响政府可用支持值。 未来清洁能源项目必须注意确保适当文档并遵守这些条款Finally, many IRA tax credits are pegged to a demonstration of the life-cycle emissions of the underlying facility or fuel. For instance, the value of the clean hydrogen credit varies based on the project's "lifecycle greenhouse gas emissions rate." On the high end, a 100% credit value is awarded to projects with a lifecycle emissions rate of less than .45 kilograms (kgs) of carbon dioxide equivalent (CO2e), but on the low end, projects only receive 20% of the credit value if their emissions rate is between 4 and 2.5 kgs of CO2e. Id. § 13204. Additionally, the availability of the new credit for sustainable aviation fuels depends on a certification that the applicable fuels achieve at least a 50% life cycle greenhouse gas reduction percentage compared to petroleum-based jet fuel!燃料项目再为生命周期温室气体排放量增量百分比增量增益Id.
The full implications of the IRA are yet to be understood. The law is likely to have significant implications for our energy future, leading to sharp growth in the nation's clean energy production and a decline in national greenhouse gas emissions. Though we have laid out some initial consequences, there are undoubtedly many more interpretive questions that will arise in the coming weeks, months, and years. Additionally, by subsidizing and lowering the costs of clean electricity and other low-emissions technology, the IRA could improve the benefit-cost analysis for a variety of environmental regulations, leading to more stringent and durable rules. Further, by bolstering the domestic energy industry, the IRA could alter the political economy of climate policy, creating a broader base of support for future government investments in clean energy production or greenhouse gas curtailment. Regardless of how this future unfolds, it will surely be a dynamic time for energy and environmental law and policy.
In addition to the extension of the solar investment tax credit, the IRA renews the previously expired production tax credit for solar energy and extends the credit to include qualifying facilities that begin construction before January 1, 2025. IRA § 13101. Taxpayers would also be eligible for a bonus 10% production tax credit if certain "domestic content requirements" are met or if the project is located in an "energy community." [1] The production tax credit is calculated by multiplying the amount of kilowatt-hours product by 0.3 cents or, if certain wage and apprenticeship requirements are met, 1.5 cents. Id.
Another key provision is an extension of the energy investment tax credit to include qualifying facilities that begin construction before January 1, 2025, with tax credits for geothermal energy being extended to 2035.13102. 类似于生产税抵免,纳税人有资格额外获得10%投资税抵免,如果满足某些“家庭内容”要求或项目位于“能源社区”。投资税抵免计算法是将设施投入服务成本乘以6%或如果满足某些工资和学徒需求则乘以30%。 Id. IRA包括扩展和修改45Q固碳ARA 1344. 碳捕获45Q信用额定为每公吨合格氧化碳17美元,或如果满足某些工资和学徒需求,则定值85美元。 Id. 45Q信用额也扩展至包括直接航空捕获量,并定值每公吨合格氧化碳36美元,或如果满足某些工资和学徒需求,定值180美元。 Id. IRA还包含高级能源项目信用额扩展至100亿美元,其中40亿美元预留用于 " 能源社区 " 。除其他外,该信用扩展包括水电设施、能源存储系统、重力电机和燃料电池及其相关收费基础设施、关键矿处理、精炼或回收以及用碳捕获存储设备对能源设施进行改换。 Id. em>Id. 它还将包括一个新的净化氢生产税抵免,可达60美分/千克合格净化氢,或,如果满足某些工资和学徒需求,可达3.00美分/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒
For three of these tax credits, the IRA makes a "direct pay" option available to any taxpayer claiming the clean hydrogen credit, the carbon capture credit, or the advance manufacturing production tax credit. IRA § 13801. Direct pay allows taxpayers to receive a refundable tax credit even if they don't otherwise have any tax liability to absorb the credit (e.g., the taxpayer is operating at a loss). In this way, the credit is particularly beneficial for early-stage companies. With respect to clean hydrogen and carbon capture facilities, the "direct pay" option is only available in the taxable year in which the facility is placed into service, and the four years following that. Apart from these three tax credits, the "direct pay" option is also available for a longer list of other energy-related credits, but only if the organization claiming them is a tax-exempt organization, state or local government, tribal government, or the Tennessee Valley Authority. Id.
The IRA includes a provision that allows taxpayers to transfer certain enumerated clean-energy credits to unrelated taxpayers.[2] IRA § 6418(a). Consideration paid for a transferrable credit must be paid in cash, and is not includable in the income of the transferor, nor deductible by the transferee. Id. § (b). Excessive transferability payments could result in an addition to tax of the transferee equal to the sum of the excessive payment amount plus a penalty of 20% of the excessive payment amount. Id. § (g)(2). This provision is particularly beneficial for taxpayers with low tax liability that cannot otherwise take advantage of the direct pay option for credits other than the three enumerated above, and instead have to turn to the tax equity markets to facilitate use of the credits.IRA创建或扩展多项附加税收抵免,包括:(1)清洁电生产抵免,§13701清洁电投资信用第13702条3)与低收入社区连通的太阳能和风能信用第13103节+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++有大量就业领域提取、处理、运输或存储化石燃料自2000年起关闭煤矿自2009年起煤厂停产或停产的普查段