IRS 45Z Hearing Recap: What Treasury’s Questions Signal for the Final Clean Fuel Credit Rule

Short summary

Treasury and IRS held a public hearing on the Section 45Z Clean Fuel Production Credit, where officials unusually questioned nearly 20 of 78 stakeholders, signaling heightened regulatory attention. Key debated issues include expanding eligible feedstocks beyond North America, credit-value disclosure on sale documents, and narrowing the facility definition to ease prevailing wage compliance. A final rule is expected before year-end 2026, with taxpayers permitted to rely on proposed rules in the interim.

• •Treasury and IRS broke from precedent by directly questioning stakeholders at the 45Z hearing, indicating heightened scrutiny
• •Key issues include feedstock eligibility scope, recordkeeping requirements, and facility definition for PWA compliance
• •No official timeline for final rule, but industry expects one before year-end 2026; proposed rules usable in interim

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