On December 2, 2022, TCS submitted public comments to the Department of the Treasury and the Internal Revenue Service (IRS) related to the "Credit for Carbon Oxide Sequestration" (Notice 2022-57). There is mounting evidence that CCS is not economically viable nor currently a solution to decreasing the pace and impact of climate change. Given the expansion of the credit in the Inflation Reduction Act (IRA), it is critical that implementation of and adjustments to 45Q regulations limit waste, fraud, and abuse. The intent of 45Q and the whole suite of tax credits established to reduce greenhouse gas emissions is to mitigate the progress of climate change by reducing carbon emissions. In the absence of strong compliance and anti-fraud safeguards, taxpayers will not be getting what they are paying for.

The comments can be viewed below or downloaded here.