Income from Hydrogen Storage, Carbon Capture, Advanced Nuclear, Hydropower, and Geothermal Energy Added to Qualifying Income of Certain Publicly Traded Partnerships
Section 70524 · Sec. 70524 ·
What this chapter is about
This part widens what counts as qualifying income for some traded partnerships. It adds hydrogen storage and carbon capture. It adds power from advanced nuclear, water and heat from the ground. The change starts with tax years after December 31, 2025.
The section rewrites section 7704(d)(1)(E) of the Internal Revenue Code of 1986 to restructure the list of qualifying activities and to bring in the transportation or storage of named fuels, alcohol fuel, biodiesel and sustainable aviation fuel, and of liquified or compressed hydrogen.
What the document actually says
“the transportation or storage of--”
That sentence, in plain words
Moving or storing the things listed below now counts.
What this is about
One group is named fuels, such as biodiesel. The other is hydrogen, whether liquid or squeezed. Both now count as qualifying work.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
“the production of electricity from any advanced nuclear facility (as defined in section 45J(d)(2)),”
The section also brings in, for a qualified facility under section 45Q(d) at least half of whose carbon oxide output is qualified carbon oxide, the generation, availability for generation or storage of electric power there and the capture of carbon dioxide by it; the production of electricity from an advanced nuclear facility as defined in section 45J(d)(2); the production of electricity or thermal energy using only a qualified energy resource described in subparagraph (D) or (H) of section 45(c)(1); and the operation of energy property described in clause (iii) or (vii) of section 48(a)(3)(A).
What the document actually says
“the production of electricity from any advanced nuclear facility (as defined in section 45J(d)(2)),”
That sentence, in plain words
Making power at an advanced nuclear plant now counts. The tax code says what such a plant is.
What this is about
Capturing carbon at a qualified plant counts too. So does making power from water or ground heat. Running certain energy gear counts as well.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
The document says “shall apply”Who acts: Secretary of the TreasuryHow: statuteSec. 70524 in the PDF
What the document says
“The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
The section applies its amendments to taxable years beginning after December 31, 2025.
What the document actually says
“The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
That sentence, in plain words
The changes start with tax years that begin after December 31, 2025.
What this is about
Earlier tax years are not touched. The old rules still hold for them. The date is fixed in the law.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
Both things the section does: rewrite the list of qualifying activities to add the new energy sources, and fix the effective date.
The punctuation and lead-in edits that restructure the list.
The section works by amending section 7704(d)(1)(E) of the Internal Revenue Code of 1986 and points to sections 40A, 40B, 45, 45J, 45Q, 48 and 6426 of that Code, none of which is indexed here.
