Political Quotes

“I rise today to engage in a colloquy with the distinguished chairman of the Senate Finance Committee, Senator Wyden. I want to comment on the transferable tax credit provisions supporting sustainability in the bill and, in particular, the application of general limitations that already exist in current law for various tax credits. As the chairman knows, the bill includes a historic investment in tax credits and incentives to promote the development of various clean energy technologies and provides a broad regime to permit eligible credits to be transferred from the project owners to another unrelated taxpayer. Under current law, the ability to claim general business tax credits is subject to a number of potential limitations in section 38 of the Tax Code based on the taxpayer's income tax liability. The bill language does not appear to apply the section 38 limitations to reduce the amount of the credit eligible to be transferred by the transferor of tax credits. This would be consistent with the goal of encouraging additional investment by expanding the availability of these tax credits to project owners without regard to their ability to claim the credits themselves. I expect that the Treasury Department will develop technical guidance for these transferable credits in a manner that reflects the intent that the section 38 limitations under current law will not apply to the transferor.”