Preparing for 45Z Without the Guidance

Cindy Zimmerman Leave a Comment

L-R: Dana Jackson, Faith Larson, Rebecca Johnson

The good news is that the Clean Fuel Production Credit (45Z) was one of the few provisions preserved from the Inflation Reduction Act in the One Big Beautiful Bill. The bad news is, there is still no guidance from the Treasury Department and no clear answer when it might be released.

What that means for ethanol producers and farmers and what steps are needed now to position for eligibility and success was the topic of a panel at last week’s American Coalition for Ethanol conference. ACE CEO Brian Jennings moderated the panel of experts which included:
Dana Jackson, RSM US LLP, Partner, Clean Energy Incentives
Faith Larson, Mickelson & Company, VP Renewables & Legal Counsel
Rebecca Johnson, CPA, Christianson PLLP, Tax and Research Senior Manager

2025 ACE - 45Z Tax Credit panel (54:26)

Rebecca Johnson with Christianson PLLP says it is frustrating to everyone to still know so little. “There’s a lot of complexity, there’s still a lot of uncertainty and we don’t have proposed guidance from the IRS…but on top of that we have a lot of people that are getting very creative within the rules that we do know and that can lead to a lot of risk in the industry,” said Johnson during an interview after the panel.

She says the main thing producers need to do is document. “Documentation is a huge thing so make sure you’re documenting everything. If you’re not sure what you need to document make sure you are reaching out to someone to get a list of things you should document,” said Johnson. “The biggest thing is don’t wait till the last minute try to make the decisions that you can and at least have a game plan come the end of the year.”

2025 ACE - Rebecca Johnson, CPA, Christianson PLLP (4:55)

2025 ACE Conference photo album

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