As of June 17, 2025, these are the changes Center for Public Enterprise is tracking in the Senate Finance Committee’s draft of the “Big Beautiful Bill.” They are not meant to be exhaustive, but rather important items to flag for the energy sector and public finance.

Sources for this summary include the bill text, the Senate Finance summary, and assessments from Evergreen, the Center on Budget and Policy Priorities, and the NYU Tax Law Center. All errors here are our own.

Changes to clean ITCs and PTCs

The clean technology ITC and PTC are phased out starting in 2026 for wind and solar projects. Solar and wind projects will receive 60 percent, 20 percent, and 0 percent of the credits respectively for starting construction in 2026, 2027, and 2028. This is a looser phaseout than in the house bill due to the reversion back to starting construction rather than a placed in service rule. The ITC is denied if a taxpayer rents or leases the property to a third party, with an exception for geothermal heat pumps. The PTC credit is denied for wind and solar leasing.

Hydropower, nuclear, and geothermal technologies are phased out starting in 2034. Those projects will receive 75 percent of the credits in 2034, 50 percent in 2035, and 0 percent if they begin construction in those respective years.

Full expensing provisions

The bill permanently extends and modifies the first-year “bonus” depreciation deduction, which is increased to 100 percent for property acquired and placed in service after January 19, 2025. The bill also allows taxpayers to deduct domestic research or experimental expenditures incurred after December 31, 2024

MACRS

The bill permanently removes clean energy project developers’ eligibility to claim the five-year MACRS accelerated depreciation schedule. Access to this five-year depreciation timeline allowed developers to write off their capital expenditures faster, reducing their tax liabilities at a faster rate and supporting higher rates of return on project development. To be sure, most clean energy developers do not have enough tax liability to monetize a tax credit or the amount of capital expenditure they could write off via accelerated depreciation. This is why developers sign tax equity partnerships with banks: They trade their tax credit and depreciation allowances to banks that can immediately monetize those benefits in return for upfront capital for project development. (Because transferability markets cannot monetize depreciation, many developers use both tax equity partnerships and transferability to get the most out of their credits.)

Removing developers’ access to five-year accelerated depreciation will make tax equity partnerships less valuable to developers and project investors. This will hurt not just renewable energy projects, but clean firm technologies, too, which are incredibly expensive and do not have a tax equity or transferability market for their tax credits. Clean firm project developers would benefit significantly from being able to claim depreciation on those costs on a five-year timeline rather than a ten- or twenty-year timeline. Now they get less upfront tax relief.

We are still studying how the end of five-year MACRS accelerated depreciation schedules for clean energy projects intersects with the return of full expensing / bonus depreciation provisions, discussed above.

FEOC

The Senate bill retains the House’s restrictive approach to foreign entities of concern and imposes requirements on additional credits: 45Y, 48E, 45X, 45Q, and 45Z. For 45Q, 45U, and 45Z in particular, credits are not allowed if the taxpayer is a specified foreign entity or, two years after enactment, if the taxpayer is a foreign influenced entity. The definitions continue to risk significant uncertainty and compliance burdens for taxpayers, rendering credits potentially unusable.

Elective pay and transferability

Elective pay or transferability were not eliminated except in so far as underlying credit rules and requirements have changed.

Elective pay projects claiming the tech-neutral ITC or PTC will now be unable to monetize the credit if they do not meet domestic content requirements. There is no safe harbor for increasing costs or supply availability. For many projects, this will make elective pay effectively unusable.

Changes to advanced manufacturing credits

The advanced manufacturing production credit is phased out for critical minerals starting in 2031. It is phased out for wind components after 2028. The advanced manufacturing investment credit is increased to 30 percent for property placed in service after 2025.

Solar components, battery components, and inverters remain untouched. The credit is disallowed for components that are integrated into other manufactured components prior to sale.

Changes to zero-emission nuclear power production credit

The zero-emission nuclear power production credit now requires taxpayers to certify that fuel use does not come from certain countries or entities. There is an exception for fuel acquired via binding contract that was in effect before January 1, 2023. These changes are in effect for tax years after December 31, 2027.

Terminated credits

The following IRA credits are terminated:

Previously-owned clean vehicle credit: Terminates the credit for vehicles acquired more than 90 days after enactment.

Clean vehicle credit: Terminates for vehicles acquired more than 180 days after enactment.

Qualified commercial clean vehicles credit: Terminates the credit for vehicles acquired more than 180 days after enactment.

Alternative fuel vehicle refueling property credit: Terminates the credit with respect to property placed in service 12 months or more after enactment.

Energy efficient home improvement credit: Terminates with respect to property placed in service 180 days after enactment.

Residential clean energy credit: Terminates with respect to expenditures made 180 days or more after enactment.

Energy efficient commercial buildings deduction: Terminates the deduction for property constructed 12 months or more after enactment.

New energy efficient home credit: Terminates for homes acquired 12 months after enactment.

Clean hydrogen production credit: Expires for facilities beginning construction after 2025.

Clean fuels credit

Extends the credit through 2031. The value for foreign feedstocks is reduced by 20 percent.

Carbon capture credit

Changes to credit parity between enhanced oil or natural gas recovery and utilization.