Transferability (Section 6418 Transfer of Certain Credits) Proposed Rule

SMART and SMACNA address transferability from two perspectives: first, as supporters of compliance with prevailing wage requirements for the protection of workers and to protect signatory contractors who comply with labor standards from underbidding

SMART and SMACNA address transferability from two perspectives: first, as supporters of compliance with prevailing wage requirements for the protection of workers and to protect signatory contractors who comply with labor standards from underbidding by violators of these prevailing wage standards; and second, as supporters of small businesses who will benefit from tax credits and create “good”[1] union jobs in communities. 


Aug 14, 2023 Regulatory Comments

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Aug 14, 2023 - SMACNA comments in support of the Internal Revenue Service’s (“IRS”) and the U.S. Treasury Department’s (“Treasury”) Proposed Rules, “Section 6418 Transfer of Certain Credits,” 88 Fed. Reg. 40496 (June 21, 2023) (hereafter “Transferability Proposed