《一揽子美丽法案》为《通胀削减法案》税收提供明确性

EquitiesEnergy Equipment &ServicesUnited StatesSamantha Hoh, CFASenior Analyst, Clean TechHSBC Securities (USA) Inc.+1 212 525 8783HSBC Global Investment Research PodcastsListen to our insightsFind out moreIssuer of report: HSBC Securities (USA) Inc.View HSBC Global Research at:https:/www.research.hsbc.com 9 Final IRA changes in One Big Beautiful Bill Actproposed by the Senate Finance Committee, which offered some relief (18 June 2025) fromHouse Republicans' heavy-handed approach (20 May 2025). For example, the Senate voted tomodify the 45Q carbon oxide sequestration credit for the “Enhancement of America-First EnergyPolicy", increasing the tax credit for CO2 used for enhanced oil and gas recovery frommaintained IRA rules on tax transferability and for projects to"begin construction"instead of“putinto service", but maintained the House's restrictions on foreign entities of concerns (FEOC).measure of clarityand stabilityfor Ustax policyin the nearterm.Senate FinanceIRAHouse-passed billCommitteeEndPhasedownTerminationProposedFinal OBBBA rulesTerminationYE 2025Construction starts by YE 202790 days after bil'sEffective YE 2025passaqe12 months afterYE 2025bil's passagePlaced inserviceby30June2026180 days afterAcquired by 30 September 2025Placed in service by YE 2025YE 20322033-34bils passageExpenditures made by YE 202512 months afterConstruction starts by 30 June 2026bill's passageNo mention12 months after9bill's passageConstruction starts by 30 June 2026180 days after* Acquired by 30 September 2025YE 2026* No carve out for automakers that had yet to sellbils passage200,000 eligible vehiclese2027YE 2031YE 2031ExtendsthroughYE2029C* Preserves IRA rules for nuclear, geothermal, hydroSand other technologies but wind & solar to begin2033 100%Start constructionSolar & Wind:微信YE 20322034 75%within 60 days of202660%20272035 50%bil's passage2027 20%* Exceptions for 1GW+ wind & solar partially on2036 0%2028 0%federal land with "right-of-way grant or lease* Adds 30% ITC for fuel cell property, nuclear energycommunity for 45YSenate FinanceIRAHouseCommitteeEndPhasedownPhasedownProposedFinal ruleschanges2029 80%2030 60%Introduce newMaintains IRA rules but imposes restrictions on use of2031 40%restrictionsimported nuclear fuel after YE 20272032 0%Eliminates IRA's distinction for use or storage in favorIntroduce parityof"parity for equipment placed in service after 4 July:withthe higherUSD85/toncreditalso applicableforenhanced oil and gas recovery or other permitted use2030 75%2029 80%Critical minerals:* Preserves IRA rules for battery storage, geothermal,YE 20322031 50%2030 60%203175%hydro and nuclear but early phasedown for wind and2032 25%2031 40%2032 50%later phasedown for critical minerals2033 0%2032 0%203325%* Maintains House termination date of YE 2027 for2034 0%wind turbines and subcomponentsWind: YE 2027*Eliminates IRA's permanent PTC of 10% for the costWind: YE 2027of refining or recycling critical minerals20352029 6%2030 5.2%Reverts back to IRA rules but impose new domestic20314.4%content requirements for geothermal heat pump2032 0% Incremental tax relief for hydrogen, fuel cells, and SAFIn contrasttotheHouse-passedbill,SenateRepublicansvotedforincremental taxreliefforseveral IRA credits. Notably, Senate Republicans extended the termination deadline for boththe 45V clean hydrogen and 45Z clean fuels production tax credits (PTC) by two years versusthe House-passed bill and IRA, respectively. Construction on clean hydrogen productionfacilities must begin construction by the end of 2027 to claim the 10-year PTC (seeUS Hydrogen: Treasury finalizes rules for 45V clean H2 PTC, 6 January 2025), which is fiveyears earlier than the IRA intended but two years later than the House or Senate FinanceCommittee proposed. BBB also extends the 45Z PTC for clean transportation fuels andsustainable aviation fuel (SAF) by two years from 2027 previously through 2029. This is twoyearslessthanthefouryearextensionproposedbytheHouseandSenateFinanceCommittee,but along with changes in the 45Q carbon oxide sequestration credit represents the lone taxcredits to secure net positive federal support from the BBB.BBB tax changes drive net federal "savings"The Joint Committee on Taxation (JCT) estimates the two year extension of the 45Z clean fuelsPTC will cost the federal government USD26bn in lost revenue. Amending the 45Q carbonoxide sequestration credit to provide parity for CO2 use and storage will cost an additionalUSD14bn between 2025-34, bringing the total cost for these two credits to USD40bn. However,the increased cost of America-First energy policy is more than offset by "savings" from"Termination of Green New Deal Subsidies", as the JCT estimates Title VIl Chapter 5 of theBBB could save the federal government a total of USD500m over the next 10 years (relative tocurrent rules).IRA tax credit (expenditures)/savings by program (USDbn), relative to current rules2502550752025202620272028202920302031203220332034The largest savings stem fro