This bill amends the Internal Revenue Code of 1986 to significantly expand the definition of "qualifying income" for publicly traded partnerships (PTPs). The primary purpose is to allow a broader range of clean energy and sustainable fuel projects to utilize the PTP tax structure, which generally requires at least 90% of gross income to be qualifying income to avoid corporate taxation. This expansion aims to facilitate investment in these critical energy sectors. The proposed changes extend qualifying income to include revenue from various clean energy generation and storage activities. This encompasses income from the generation of electric power or thermal energy using qualified energy resources, the operation of energy property , and the storage of electric power or thermal energy using advanced technologies. It also covers income from the generation, storage, or distribution of electric power or thermal energy from combined heat and power systems, as well as the processing of biomass or municipal solid waste. Additionally, the bill broadens qualifying income to include activities related to sustainable fuels and carbon management. This covers the transportation or storage of certain low-carbon fuels , such as liquified hydrogen, and the conversion of renewable biomass into renewable fuels. Income from the production, storage, or transportation of fuels from captured carbon oxides that achieve substantial greenhouse gas emission reductions is also included. Finally, the bill extends this treatment to income from advanced nuclear facilities , qualifying gasification projects , and facilities engaged in carbon capture , along with the production, storage, or transportation of specific renewable chemicals . These amendments are set to take effect for taxable years beginning after December 31, 2025.
This bill amends the Internal Revenue Code of 1986 to significantly expand the definition of "qualifying income" for publicly traded partnerships (PTPs). The primary purpose is to allow a broader range of clean energy and sustainable fuel projects to utilize the PTP tax structure, which generally requires at least 90% of gross income to be qualifying income to avoid corporate taxation. This expansion aims to facilitate investment in these critical energy sectors. The proposed changes extend qualifying income to include revenue from various clean energy generation and storage activities. This encompasses income from the generation of electric power or thermal energy using qualified energy resources, the operation of energy property , and the storage of electric power or thermal energy using advanced technologies. It also covers income from the generation, storage, or distribution of electric power or thermal energy from combined heat and power systems, as well as the processing of biomass or municipal solid waste. Additionally, the bill broadens qualifying income to include activities related to sustainable fuels and carbon management. This covers the transportation or storage of certain low-carbon fuels , such as liquified hydrogen, and the conversion of renewable biomass into renewable fuels. Income from the production, storage, or transportation of fuels from captured carbon oxides that achieve substantial greenhouse gas emission reductions is also included. Finally, the bill extends this treatment to income from advanced nuclear facilities , qualifying gasification projects , and facilities engaged in carbon capture , along with the production, storage, or transportation of specific renewable chemicals . These amendments are set to take effect for taxable years beginning after December 31, 2025.