What Notice 2024-48 Provides
Treasury and the IRS released Notice 2024-48, detailing the information taxpayers need to determine eligibility for the Statistical Area Category and the Coal Closure Category under prior guidance in Notice 2023-29. Both categories support qualification for the Energy Community Bonus Credit, enacted as part of the Inflation Reduction Act of 2022.
The notice includes:
- Appendix 1 — the qualifying list under the Statistical Area Category
- Appendix 2 — the qualifying list under the Coal Closure Category
These appendices function as the operative reference for taxpayers evaluating whether a project site meets the geographic conditions necessary to claim the bonus credit.
Updated FAQs
Alongside the notice, the IRS refreshed its energy-community FAQs, adding clarifications on how the bonus credit interacts with related provisions and how the agency will treat ambiguous fact patterns. Practitioners should rely on the FAQs for day-to-day interpretive questions that do not require formal guidance.
Implications
Projects in prospective energy-community locations should be re-underwritten against the updated lists. Developers and their tax advisors should document siting diligence early, since eligibility hinges on verifiable geography at the time the credit is claimed.