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Section 3610 of the CARES Act Extended Until March 31, 2021

Client Alert | 1 min read | 12.30.20

On Sunday, President Trump signed a combined COVID-Relief and Omnibus Spending Bill, The Consolidated Appropriations Act of 2021, which funds the Federal Government for FY 2021 and includes a variety of COVID-19-related relief measures.  Among those measures, Section 1002 of the Act extends the reimbursement period for Section 3610 of the CARES Act, which allows federal agencies to use their funds to reimburse contractors for paid leave made to employees who are unable to access the worksites and unable to telework during the pandemic. The initial reimbursement cutoff of September 30, 2020 was previously extended until December 11, 2020, and the Act further extends the period until March 31, 2021, allowing agencies the discretion to continue to provide contractors with relief under Section 3610 of the CARES Act in 2021.

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Client Alert | 3 min read | 10.15.25

Developers Adapt Timelines and Strategies for Wind and Solar Projects Following Recent IRS Guidance and Expected IRS Enforcement Activity

On August 15, 2025, the Treasury Department and IRS released updated guidance concerning Beginning of Construction requirements to qualify for clean energy tax credits. This new guidance is critical for developers to consider as they rush to qualify for the tax credits before they expire entirely. The much-anticipated guidance followed the July 7, 2025 Executive Order 14315, Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources (“July 7, 2025 Executive Order”), which signaled that the Trump Administration was planning to strictly enforce the termination of production and investment tax credits for solar and wind facilities that are set to expire under the One Big Beautiful Bill Act (OBBB Act), covered in more detail here. The new guidance comes at a time when many in the industry are struggling to keep up with the myriad ways that the new administration is working to roll back wind and solar tax credits, leaving developers to piece through the recent guidance to determine how best to structure and invest in clean energy projects given the volatile position of the current administration vis-a-vis wind and solar energy....

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