On November 17, 2023, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking (the “NPRM”) with respect to Proposed Regulations under section 48 of the Internal Revenue Code of 1986 (the “Code”).  The NPRM addresses the Investment Tax Credit (“ITC”) framework, as amended under the Inflation Reduction Act (the “IRA”).  This blog…