Energy Credit Guidance: Treasury and IRS Issue Proposed Regulations Under the Clean Fuel Production Credit

On February 4, 2026, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under Section 45Z, the clean fuel production credit. Enacted by the Inflation Reduction Act of 2022 (IRA) and subsequently amended and extended by the One Big Beautiful Bill Act (OBBBA), Section 45Z replaces prior federal fuel incentives with a unified credit regime based on lifecycle greenhouse gas (GHG) emissions and establishes a... By: Perkins Coie