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IRS the New DOL?

黑料不打烊 warns the IRS to look before it leaps into quickly rolling out prevailing wage and apprenticeship requirements鈥攆or which it has no internal expertise or experience鈥攖ied to new private development tax credits in the Inflation Reduction Act.

On November 4, 黑料不打烊 provided the IRS with extensive  on a notice from the U.S. Department of the Treasury seeking public comments on  tied to clean energy tax incentives鈥攁mong others鈥攊n the Inflation Reduction Act (IRA). The notice marks the first step in outlining how contractors must comply with prevailing wage and registered apprenticeship requirements for projects to be eligible for the full value of the tax incentives.

For the full credit, contractors will have to begin meeting the requirements 60 days after final guidance is issued. 黑料不打烊 advised the agency to not rush incomplete guidance that might trigger the 60-day clock for compliance, but to instead develop truly thoughtful and comprehensive guidance through proper rulemaking so that owners and contractors can understand and meet these unique requirements.

黑料不打烊 also pointed out that while similar requirements have been tied to various federal, state, and local public works projects, for the first time ever, prevailing wage and apprenticeship requirements will now be required on particular private projects. Likewise, Treasury and owners will also for the first time ever have to understand, regulate, or comply with these requirements to receive the full benefits under the IRA.

黑料不打烊 stressed that these unprecedented provisions require thoughtful and comprehensive analysis as the IRS comes to fully understand the complexity and challenges contractors will face meeting the requirements.  黑料不打烊 will continue to work with Treasury and the IRS as it develops further guidance regarding these new labor requirements.

For more information, contact Claiborne Guy at claiborne.guy@agc.org or 703-837-5382.

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