Ms. Porter,

The National Association of Bond Lawyers (“NABL”) appreciates the swift work of the Internal Revenue Service (IRS) and U.S. Department of Treasury to provide guidance pertaining to tax law changes made by the Inflation Reduction Act of 2022 (Pub. L. 117-169). We now wish to provide additional comments, attached, to supplement those made in our November 4, 2022, letter responding to IRS Notice 2022-49, “Request for Comments on Certain Energy Generation Incentives;” and Notice 2022-50, “Request for Comments on Elective Payment of Applicable Credits and Transfer of Certain Credits.”^[1]

NABL is a nonprofit organization and specialty bar association of approximately 2,500 lawyers whose purposes include, among other things, providing advice and comment at the federal, state, and local levels with respect to legislation affecting state and municipal obligations. NABL believes that participating in the guidance process supports clarification of, and facilitates compliance with, tax laws and regulations. The following comments were prepared by a working group of the NABL Tax Law Committee (whose members are listed in Appendix 1 hereto) and were approved by the NABL Board of Directors.

Thank you in advance for your time and attention on this important matter.

Best,

Joseph (Jodie) E. Smith

President
National Association of Bond Lawyers (NABL)

CC:

• Lily Batchelder, Assistant Secretary for Tax Policy, U.S. Department of Treasury
• Brett York, Deputy Tax Legislative Counsel, U.S. Department of Treasury
• Helen Hubbard, Associate Chief Counsel, CC:FIP, Internal Revenue Service
• Jian H. Grant, Branch Chief, CC:FIP:B5, Internal Revenue Service

---

In Reference To

---

Learn More