Late last week, the Internal Revenue Service (“IRS”) and Department of the Treasury released final regulations relating to transfers of certain tax credits pursuant to Section 6418 of the Code (the “Code” and, such rules, the “Final Tax Credit Sale Rules”). The release of the Final Tax Credit Sale Rules follows the issuance of proposed regulations in June 2023, a comment period, and a public hearing (the “Proposed Tax Credit Sale Rules”). The Final Tax Credit Sale Rules largely adopt the Proposed Tax Credit Sale Rules, with a few minor exceptions.
