AEA Leads Coalition Letter to Treasury and IRS Urging Updated Guidance

WASHINGTON DC (8/6/25) – Today, a coalition of 16 organizations, led by the American Energy Alliance, sent a letter to the U.S. Department of the Treasury and the Internal Revenue Service (IRS) providing suggestions on how to carry out the statutory language of the recently enacted One Big Beautiful Bill Act (H.R. 1, “OBBBA”). The text of the letter and the list of signers are available here.

American Energy Alliance President Tom Pyle released the following statement:

“The Big Beautiful Bill’s passage into law marked a pivotal shift in federal energy tax policy; the IRA guidance needs to reflect that change to follow the text and intent of the law. We, as an organization, have said repeatedly that in order to follow the law, the administration needs to tighten Treasury rules. Ensuring that legitimate efforts are made to start construction and not allowing the gamesmanship the Obama administration enabled will ensure that the energy subsidy lobby doesn’t continue to game the system at the public’s expense. Congress did its job to promote energy reliability and end the subsidy gravy train. Now it’s the administration’s turn to implement these reforms in good faith and carry them out as intended.” 

Key points from the letter:

• Calls for the IRS to eliminate the Five Percent Safe Harbor and instead require actual physical construction of electrical generating equipment.
• Explains that IRS notices cited in the OBBBA apply only to foreign entity rules—not to the production or investment credits.
• Requests stronger standards for “beginning of construction” and “continuous program of construction” that reflect the new law and the administration’s directive.
• Urges clear guidance that all qualifying projects must be placed in service by December 31, 2027, regardless of start date.

AEA Experts Available For Interview On This Topic:

• Tom J. Pyle, President
• Kenny Stein, Vice President of Policy
• Alex Stevens, Manager of Policy and Communications

Additional Background Resources From AEA:

• Coalition Letter to Treasury and IRS Suggesting Updated Guidance
• Big Beautiful Bill Headed to the President’s Desk
• What The One Big Beautiful Bill Means for American Energy

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