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New IRS Form 7220 Adds Compliance Complexity to Clean Energy Tax Credits

New IRS Form 7220 Adds Compliance Complexity to Clean Energy Tax Credits

According to a recent LinkedIn post from Concentro, the Internal Revenue Service has introduced Form 7220 for the 2025 tax year, affecting projects seeking the prevailing wage and apprenticeship–enhanced investment tax credit rate. The post indicates that the full 30% ITC now depends on correctly completing and attaching this form for each eligible facility.

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The company’s LinkedIn post highlights that Form 7220 requires ongoing annual filings while prevailing wage requirements apply, and calls for detailed reporting on wages, apprentice hours, deficient hours, and cure payments. The post suggests that developers may face administrative and compliance burdens, with potential timing and documentation risks around filing season.

As shared in the LinkedIn post, Concentro notes that Form 7220 has implications not only for project sponsors but also for buyers of tax credits, who are encouraged to address PW&A documentation in transaction agreements. For investors, this added compliance layer could influence deal structures, diligence costs, and pricing for transferable clean energy tax credits in 2025 and beyond.

The post also points to educational resources Concentro has prepared on how Form 7220 works in practice, which may position the firm as an advisory resource in the evolving clean energy tax credit market. If the firm successfully converts this expertise into client engagements, it could benefit from increased demand for specialized tax and transaction support tied to ITC compliance.

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