Comment from CFO Services
CFO ServicesSupportBusiness
Summary: CFO Services, a tax consulting firm, supports the proposed regulations for the Section 45Z clean fuel production credit, particularly the inclusion of purchaser certificate and emissions rate safe harbors. They argue that these safe harbors are essential for providing audit certainty and administrative efficiency, though they also request additional clarification on how non-owner producers can substantiate prevailing wage and apprenticeship requirements.
RE: Comments Regarding Proposed Regulations Regarding Section 45Z Clean Fuel
Production Credit (REG-121244-23)
Treasury Department and Internal Revenue Service
CFO Services is a tax consulting firm that works with technology and manufacturing
companies across the country. We have extensive experience and technology to provide
a broad range of services to help companies identify and document federal, state, and
local incentives. Our Federal Incentives team focuses on R&D, energy credits,
technology credits, and manufacturing incentives, whereas our Multi-State Credits &
Incentives team concentrates on successful collaboration with state and local
representatives to capture statutory and discretionary incentives.
We are excited to submit these comments in response to the proposed regulations,
with the goal of supporting our clients in meeting compliance obligations and providing
feedback to help develop a clear, workable, and effective incentive program.
We address the following sections of the proposed regulations presented in the 45Z
Notice of Proposed Rulemaking.
Challenges of Complying with PWA Requirements under Section 45Z [1.45Z-4(e)]
Use of Certificates for Qualified Sales to Provide Audit Certainty [1.45Z‑4(g)(3)]
Safe Harbor Verification and Audit Certainty [1.45Z‑4(g)(2)]