A&O Shearman, established in 2024 through the merger of Allen & Overy and Shearman & Sterling, combines legal expertise to serve clients globally. The firm's focus is on complex, multijurisdictional matters, guiding clients through the evolving landscape of global business. With a team of nearly 4,000 lawyers, A&O Shearman operates in various legal systems, including English and U.S. law. On December 4, 2024, the U.S. Treasury Department and IRS issued final regulations defining 'energy property' and outlining rules for energy credits, particularly the Investment Tax Credit (ITC). These regulations, effective for projects starting after December 12, 2024, offer improved terms for energy projects but add complexity in determining project completion. The regulations under Section 48 of the Internal Revenue Code aim to enhance the ITC, addressing changes introduced by the Inflation Reduction Act of 2022. They expand the types of assets eligible for the ITC and introduce criteria related to domestic content and energy community involvement. Notably, the regulations impact the treatment of costs for qualified interconnection property and clarify eligibility criteria for cleaning and conditioning equipment under the ITC. The 'energy project' definition now requires four aggregation factors to group multiple energy properties, aiming to streamline project evaluation. While the final regulations don't apply retroactively, taxpayers may choose to adopt them. Projects placed in service post-December 12, 2024, are subject to the new rules, emphasizing the need for careful project assessment. Overall, the regulations aim to incentivize energy investments while ensuring compliance with evolving standards in the energy sector.