The Inflation Reduction Act Survey – we need your opinion!

Ally WetheraldLegislative Alerts, Uncategorized

In August, the U.S. Department of Treasury and Internal Revenue Service issued a proposed rule regarding the implementation of the Inflation Reduction Act. This legislation is strongly opposed by ABC, and we’re launching a survey to get your opinion.

The proposed Inflation Reduction Act provides over $270 billion in tax credits for the construction of a variety of clean energy projects. The proposed rule provides additional regulations regarding prevailing wage and apprenticeship requirements attached to these tax credits. Unfortunately, many of these regulations are unclear. For instance, the guidance states that taxpayers must maintain books of records to establish that prevailing wages are paid and that apprenticeship requirements are met. But the Treasury offers no explanation as to what records should be kept or how the requirements will be enforced.

Many other aspects of this potential legislation are troubling. We have found that many of the new clean energy construction classifications are not yet posted in the Department of Labor’s wage determinations covering many areas of the country. And if that information is not available online, taxpayers must contact the Department of Labor’s Wage and Hour Division directly via email to request a wage determination or rate. It is unclear how long that process will take before work can begin. And the developer/taxpayer faces considerable penalties if prevailing wage and registered apprenticeship requirements are not met!

Here’s how you can help in pushing back on the concerning aspects of the proposed rule:

First, learn more about the proposed legislation at Then, take the survey here:

The survey will close on Oct. 2 at 5 p.m. ET. ABC will be submitting comments on the proposal, and your voice is critical to drafting an informed and effective response that will be sent to the Treasury Department.

Please reach out to Michael Altman at with any questions or comments.