Treasury Seeks Comments on Proposed 25C Tax Credit PIN Assignment System

The US Department of the Treasury and the Internal Revenue Service are seeking public comment on their proposed production identification number (PIN) assignment system for certain products under the 25C Energy Efficient Home Improvement tax credit.¹ Industry stakeholders are encouraged to provide feedback on the proposed PIN assignment system by February 27, 2024. 

As you may know, the Inflation Reduction Act (IRA) of 2022 extended the 25C tax credit through the end of 2032 and expanded the credit to allow households to deduct 30% of the costs of eligible activities (including energy audits) from their taxes while adding new qualified products, larger total dollar caps, and making the credit available annually. Download BPA’s 25C Tax Credit Fact Sheet for more details. 

The IRA’s extension and expansion of 25C included a new statutory requirement (set to begin in 2025) for taxpayers to include a product identification number (PIN) on their tax return to receive a credit for their equipment. When the requirement takes effect, certain products can only qualify for the 25C tax credit if they are produced by a qualified manufacturer and if the taxpayer includes the qualified PIN of the item on their tax return. Treasury and the IRS have now proposed a draft PIN assignment system for eligible products and are seeking feedback.

The proposed PIN assignment system will apply to the following products under 25C starting in 2025 (provided they meet certain efficiency standards): 

• Electric or natural gas heat pump water heaters 
• Electric or natural gas heat pumps 
• Central air conditioners 
• Natural gas, propane, or oil water heaters 
• Natural gas, propane, or oil furnaces/hot water boilers 
• Certain Biomass stoves or boilers. 
• Certain oil furnaces and hot water boilers 
• Certain panel boards, sub-panelboards, branch circuits, or feeders that enable installation and use of the other products listed
• Exterior windows and doors (including skylights) 

Questions from the U.S. Treasury and IRS soliciting public comment appear on pages 9-10 and 12-16 of the notice. Comments may be submitted either electronically via the Federal eRulemaking Portal at https://www.regulations.gov/document/IRS-2024-0003-0001, or by mail to Internal Revenue Service, CC:PA:LPD:PR (Notice 2024-13), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Comments will be posted publicly. 

1. This summary is for informational purposes only and is designed to advise based on legislation, guidance, and draft policy proposals released by the U.S. Department of the Treasury and the Internal Revenue Service (IRS). The Building Performance Association is not offering tax advice and the information provided in this document should not be relied upon as legal or accounting advice. ↩︎