On November 4, 2022, TCS submitted public comments to the Department of the Treasury and the Internal Revenue Service (IRS) related to "Elective Payment of Applicable Credits and Transfer of Certain Credits" (Notice 2022-50), particularly changes made to the credit for carbon oxide sequestration determined under § 45Q in the FY 2022 budget reconciliation bill, commonly referred to as the Inflation Reduction Act (IRA).

TCS's comments to Treasury/IRS can be downloaded here or read below.