Jennifer Bernardini, a managing director at PwC with over 20 years in federal energy tax incentives, discusses the dramatic shifts brought by the One Big Beautiful Bill Act. She unpacks new compliance requirements and the implications for energy credits, especially for wind and solar projects. The conversation highlights urgent actions companies need to take to maximize opportunities and navigate potential pitfalls amid changing regulations. Tune in for insights on how to thrive in the evolving landscape of renewable energy tax credits.
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insights INSIGHT
Credits Survived But Rules Changed
The One Big Beautiful Bill reshaped but did not eliminate IRA energy tax credits.
Taxpayers must now prioritize compliance with new requirements to access credits.
insights INSIGHT
FIAC Is The Major New Constraint
The largest new requirement is the foreign entity of concern (FIAC) restrictions targeting supply-chain influence.
FIAC aims to limit involvement from China, Russia, North Korea, Iran and listed entities in energy projects.
insights INSIGHT
Three FIAC Tests To Know
FIAC contains three tests: ownership, effective control, and material assistance.
These tests require detailed ownership and counterparty analysis for credit claimants and transferees.
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The Inflation Reduction Act introduced a broad range of renewable energy tax credits. Now, the One Big Beautiful Bill Act (OB3) has reshaped these incentives with new compliance requirements, shifting timelines, and selective phaseouts. In this podcast, we cover what’s changed, what’s stayed the same, and the implications for companies navigating the evolving renewable energy tax credit landscape.
In this episode, we discuss:
1:51 – Significant changes to energy credits from OB3
9:28 – Energy credit modifications, early sunsets, and what remains unchanged
14:07 – New guidance for wind and solar industry clean electricity credits
21:14 – Immediate actions for companies to maximize opportunities under OB3
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About our guest
Jennifer Bernardini is a managing director in PwC’s Washington National Tax practice. She has over 20 years of experience implementing federal energy tax incentives that support the development of renewable energy and the climate transition.
About our guest host
Guest host Diana Stoltzfus is a partner in the National Office who helps to shape PwC’s perspectives on regulatory matters, responses to rulemakings and policy development, and implementation related to significant new rules and regulations. Prior to rejoining PwC, Diana was the Deputy Chief Accountant in the Office of the Chief Accountant (OCA) at the SEC where she led the activities of the OCA’s Professional Practices Group.
Transcripts available upon request for individuals who may need a disability-related accommodation.Please send requests to us_podcast@pwc.com
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