Highlights

• The Inflation Reduction Act (IRA) significantly changes the tax code to incentivize companies to invest in energy security, reduce carbon emissions and increase energy innovation.
• To maximize the value of the tax credits contained in the IRA, companies must follow labor rules that include paying specific workers a "prevailing wage" and employing a certain number of registered apprentices.
• The IRA generally provided that these labor rules go into effect 60 days after the U.S. Department of Treasury and Internal Revenue Service (IRS) issue guidance. The guidance was issued on Nov. 29, 2022, starting the 60-day clock.

President Joe Biden signed the Inflation Reduction Act (IRA) into law on Aug. 16, 2022. The massive legislative package revises policy on taxes, healthcare, agriculture and energy. In particular, the IRA modifies and expands existing credits and creates new tax credits for a variety of renewable energy and carbon capture industries and projects. In many cases, these provisions provide a "bonus credit" if certain labor rules are met. These labor rules contain both prevailing wage and apprenticeship rules. Under the statute, these labor rules go into effect 60 days after the U.S. Department of Treasury and Internal Revenue Service (IRS) issue guidance.

A full description of the IRA can be found in a previous Holland & Knight alert, "The Inflation Reduction Act: Summary of the Budget Reconciliation Act," published on Aug. 8, 2022. Background on the...

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