Prohibited Foreign Entities
Manufacturing
Monetization
Energy Tax Resource Library
Sections 48C and 45X
Manufacturing
Two tax credits – the Section 48C Qualified Advanced Energy Project Credit and the Section 45X Advanced Manufacturing Production Credit - were designed to encourage the investment in domestic manufacturing. The Section 48C tax credit is an allocated credit; the total $10 billion has already been allocated taxpayers and no further allocations are available. The Section 45X tax credit is based on taxpayers’ production; the One Big Beautiful Bill, signed by the President in July of 2025, significantly revised the Section 45X tax credit, including shortening the availability of the tax credit for taxpayers producing wind components and adding prohibited foreign entity restrictions. For more information see "One Big Beautiful Bill Act to Scale Back Clean Energy Tax Credits Under Inflation Reduction Act," (Holland & Knight Alert, June 30, 2025).