IRS Releases First “Annual Table” of CEIC-Eligible Technologies

The IRS released Rev. Proc. 2025-14 on January 15th 2025. This Rev. Proc. contains the first official “Annual Table” of technologies with net-neutral greenhouse gas (GHG) emissions rates. Facilities that fall into the listed categories will automatically qualify for the Clean Energy Investment Credit (CEIC). Solar facilities are listed of course, but many other technologies also make the grade

The Background:

Let’s start with a few definitions to set the stage. Don’t worry if it’s been a while since your last science class — we’ll keep it simple.

• Greenhouse Gas Emissions (GHG): Gases released when fossil fuels are burned, which trap heat in the Earth’s atmosphere, contributing to global warming
• Combustion: The process of burning a fuel to produce heat, which is then used to generate electricity
  • o Associated GHG emission rates are high
• Gasification: The process of chemically converting a solid fuel into a gaseous fuel, which is then used to generate electricity
  • Associated GHG emission rates are lower than those generated by combustion but still generally above zero
• Combustion and Gasification Facility (C&G): A facility that produces electricity via combustion or gasification
  • Examples include facilities that involve biogas, biomass, or renewable natural gas
  • Technologies including fuel cells and microgrid controllers may be considered C&G facilities, if the cell or grid is combustion-fueled
• Non-C&G Facility: A facility that does not use combustion or gasification to produce electricity
  • A solar-powered facility is the classic example
  • These facilities have net zero GHG emissions

The Credit The Sec. 48 Investment Tax Credit (ITC) and the Sec. 48E Clean Energy Investment Credit (CEIC) are two versions of a federal incentive supporting the growth of renewable energy properties. The date on which construction commenced determines which version is in play:

• Construction began before 1.1.2025: ITC-eligible
• Construction began after 1.1.2025: CEIC-eligible Both versions are dollar-for-dollar Credits that can directly reduce tax liability by 30% or more.

The key difference is that the CEIC is “tech-neutral,” meaning that qualifying technologies must have a net greenhouse gas emissions rate of no greater than zero. This will exclude C&G-type properties from eligibility moving forward.

So, if C&G type technologies are ineligible for the CEIC, what technologies are eligible? Enter the IRS’ first “Annual Table.”

The Table This table lists the greenhouse gas emission rates for eight types of technologies. Any facility that is of a type or category listed in the table is eligible for the CEIC Credit under Sec. 48E. 

These technologies are all non-C&G facilities as described above, with associated GHG emissions of no greater than zero.

The Implications for Taxpayers

So what do taxpayers and their advisors need to understand?

• If a technology is listed on the table, any facility of that type is eligible for the CEIC.
• If a technology is not listed on the table, a facility of that type might be eligible, but you’ll have to prove that the technology has a zero-emissions rate.
• This table can be relied upon until the next Annual Table is released. Future tables might add or remove different types of facilities.
• Moving forward, taxpayers should rely on the Annual Table that was in effect at the time construction of their facility began.

If you’re considering incorporating renewable energy systems into your property, it’s important to know what technologies are in play and what associated Credits are on the table. We’re here to help.