§48E rate: 6% base, 30% with wage/apprenticeship or under 1 MW AC
The clean electricity investment credit is 6% of the qualified investment, or 30% for a facility or storage system with a maximum net output under 1 MW (AC) or one that meets the prevailing-wage and apprenticeship requirements (§48E(a)(2)).
Sources: 26 U.S.C. §48E (Clean electricity investment credit), as amended by Pub. L. 119-21 §§70512–70513 (read 2026-09-24)
Solar and wind: begin construction by 2026-07-04 or be in service by 2027-12-31
§48E does not apply to wind or solar property placed in service after December 31, 2027 (§48E(e)(4)). Under Pub. L. 119-21 §70513 that termination applies only to facilities whose construction begins more than 12 months after July 4, 2025, so a facility that began construction by July 4, 2026 keeps the credit. Storage placed at a solar or wind facility is excepted (§48E(e)(4)(C)).
Sources: 26 U.S.C. §48E (Clean electricity investment credit), as amended by Pub. L. 119-21 §§70512–70513 (read 2026-09-24) · Pub. L. 119-21 (One Big Beautiful Bill Act), 139 Stat. 72, July 4, 2025 (read 2026-09-24)
Storage keeps §48E through 2033, then phases down
The applicable year is 2032 (§45Y(d)(3)). Storage that begins construction through 2033 keeps 100% of the credit, 75% in 2034, 50% in 2035 and 0% from 2036 (§48E(e)(1)–(2)).
Sources: 26 U.S.C. §48E (Clean electricity investment credit), as amended by Pub. L. 119-21 §§70512–70513 (read 2026-09-24) · 26 U.S.C. §45Y(d)(3) (applicable year = 2032) and (g)(12) (elective-payment phase-out) (read 2026-09-24)
Beginning-of-construction evidence is an attestation
IRS Notice 2025-42 (physical-work test only) was vacated on June 6, 2026 (D.D.C. No. 25-4400), restoring the 5% safe harbor pending appeal; a reversal could apply retroactively. The resolver takes the construction-start date as a user attestation — confirm it with tax counsel.
Sources: Oregon Environmental Council v. IRS, No. 25-4400 (D.D.C. June 6, 2026) vacating Notice 2025-42 (McGuireWoods summary) (read 2026-09-24)
Prohibited-foreign-entity (FEOC) material-assistance test
For construction beginning after December 31, 2025, no credit is allowed if the project receives material assistance from a prohibited foreign entity: its material-assistance cost ratio must be at least the threshold for the year construction begins — qualified facilities 40% (2026), 45% (2027), 50% (2028), 55% (2029), 60% (after 2029); energy storage 55%, 60%, 65%, 70%, 75%. Specified-foreign and foreign-influenced taxpayers are barred outright (§48E(d)(6)).
Sources: 26 U.S.C. §7701(a)(52)(B) (material-assistance threshold percentages) (read 2026-09-24) · 26 U.S.C. §48E (Clean electricity investment credit), as amended by Pub. L. 119-21 §§70512–70513 (read 2026-09-24) · IRS Notice 2026-15, interim prohibited-foreign-entity material-assistance safe harbors (read 2026-09-24)