On January 20, President Donald Trump issued over 100 executive orders, including one titled Unleashing American Energy. This order seeks to end the “Green New Deal” and halts the distribution of federal funds appropriated through the Inflation Reduction Act and the Infrastructure Investment and Jobs Act.
At first glance, the directive might seem to suspend all clean energy-related financial support, including grants, loans, and IRS funding for implementing the IRA. However, the order specifically targets “appropriated funds”—which generally refers to budgeted spending by federal agencies rather than tax incentives.
OMB Clarifies Tax Credits Are Unaffected
In response to pushback, the Office of Management and Budget (OMB) issued a memorandum clarifying that the order applies only to programs, projects, or activities referenced in Section 2. This section focuses on federal climate policies and electric vehicle mandates but does not mention tax credits. In fact, tax credits are not addressed anywhere in the order.
A straightforward interpretation of the directive suggests that IRA tax credits, including those for renewable energy, remain outside its scope.
What This Means for IRA Tax Credits
Despite initial concerns, there is no indication that IRA tax credits—such as those eligible for elective pay under Section 6417 and transferability under Section 6418—are impacted by the funding pause.
Additionally, since these tax credits were established by law, modifying or eliminating them would require congressional action, not an executive order.
That said, the broader effects of Trump’s executive actions are still unfolding, and some are already facing legal challenges. While administrative delays may occur as agencies assess the orders’ impact, the fundamental availability of IRA tax credits remains unchanged for now.