Finding Tool For Public Comment Letters Filed Regarding The Direct Pay And Transferability Provisions (§ 6417) And Elective Credit Transfer Provisions (§ 6418) Of The Inflation Reduction Act Of 2022 - Income Tax

The IRS published Notice 2022-50 on October 10, 2022, calling for public comments on the elective payment and credit transfer provisions of the Inflation Reduction Act of 2022 (Public Law 117-169, 136 Stat. 2003 (August 16, 2022)) to be filed by November 4, 2022. Over 190 letters were filed in response. These letters contained specific comments and questions which will be available for use by the Treasury and IRS in anticipation of guidance on implementing § 6417 and § 6418.

Baker Botts has prepared this finding tool below that organizes the letters alphabetically by commenter name and lists the topics addressed in each letter. We reviewed each letter that was filed to develop our summary of the topics covered by that letter. Recognizing that browsing through the comments on Regulations.gov to find the letters of interest is very cumbersome, this is our contribution to facilitating development of the needed guidance on these new provisions. With this table, although you cannot do a word search through the text of all the letters, you can search for the letters we have indicated cover a topic of interest (for example, use Control + f to find all letters commenting on "recapture"). We hope you will find this tool useful.

Commenter Name	Signed By	Topic	Comment Document
26 Organizations	Center for American Progress Chesapeake Climate Action Network Clean Air Task Force Climate Crisis Policy Earthjustice Environmental Defense Fund Evergreen Georgia Clinicians for Climate Action GreenFaith Health Care Without Harm Healthy Air & Water Colorado League of Conservation Voters Medical Society Consortium on Climate and Health Michigan Clinicians for Climate Action National Wildlife Federation Natural Resources Defense Council RMI Sierra Club The Climate Reality Project The Earth Bill Network Union of Concerned Scientists Virginia Clinicians for Climate Action Voices for Progress WE ACT for Environmental Justice Western Organization of Resource Councils Wisconsin Health Professionals for Climate Action	Identification; monitoring; general guidance	26 Organizations Comments
ACP, ACORE, AEE, SEIA	JC Sandberg Greg Wetstone Nat Kreamer Abigail Hopper	General comments	ACP, ACORE, AEE, SEIA Comments
Advanced Energy Economy	Nat Kreamer	Eligible entities; tax-exempt entities; documentation; recapture; third-party ownership; partnership eligibility; S corporation eligibility	Advanced Energy Economy Comments
Afloat, Inc.	Afloat, Inc.	Documentation	Afloat, Inc. Comments
Air Company	Natalia Sharova	Direct Pay timing; Procedures following 5-year Direct Pay period	Air Company Comments
American Chemistry Council	Kimberly Wise White	General comments	American Chemistry Council Comments

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