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Sustainability now: Energy credits after the beautiful bill · PwC's accounting podcast

• 0:00
  SPEAKER_00: Thought leadership from PWC's national office.
• 0:07
  SPEAKER_02: Hello, and welcome to PWC's Accounting Podcast.
• 0:10
  SPEAKER_02: I'm Heather Horn.
• 0:12
  SPEAKER_02: Today we're back with Sustainability Now, turning our attention to a topic that's been making headlines in both the tax and energy sectors, the Inflation Reduction Act energy incentives.
• 0:24
  SPEAKER_02: In today's episode, we'll break down how these credits have been reshaped by the recently passed One Big Beautiful Bill Act.
• 0:31
  SPEAKER_02: While there were concerns about the repeal of all energy credits, the reality is much more nuanced with significant changes to timelines, eligibility, and new compliance considerations.
• 0:46
  SPEAKER_02: Leading today's conversation is our guest host, Diana Stoltsfist, a partner in PWC's national office, and she is joined by Jennifer Barnardini, a managing director in PWC's Washington National Tax Practice.
• 0:59
  SPEAKER_02: With that, let's listen to their conversation.
• 1:02
  SPEAKER_01: Over the past couple of years, we've seen the Inflation Reduction Act, or IRA, drive major investments in renewable energy by offering a wide range of tax credits.
• 1:12
  SPEAKER_01: These credits were designed to lower costs for companies developing clean energy projects and in turn speed up the transition to a low carbon economy.
• 1:21
  SPEAKER_01: But this summer, as Congress was deliberating the one big beautiful bill, or OB3 as it's called, the headlines were dramatic.
• 1:29
  SPEAKER_01: There was talks of repealing the IRA's energy incentives altogether.
• 1:33
  SPEAKER_01: But in the end, the credits weren't eliminated.
• 1:36
  SPEAKER_01: But the one big beautiful bill did make some significant changes.
• 1:40
  SPEAKER_01: So today I'm joined with Jennifer and we're going to break down what's really changed, what stayed the same, and what companies should be doing as they navigate this new landscape.
• 1:50
  SPEAKER_01: So maybe Jennifer, let's start with the big picture.
• 1:53
  SPEAKER_01: When OB3 passed, the biggest question was whether energy credits would survive.
• 1:58
  SPEAKER_01: They did, but the law has reshaped them.
• 2:01
  SPEAKER_01: Can you walk us through the most significant new rules?
• 2:04
  SPEAKER_03: Yes, the OB3 made several significant changes to the energy credits, but as you've caught on, the headline is that they remain viable.
• 2:11
  SPEAKER_03: There are several key changes I'd like to highlight.
• 2:14
  SPEAKER_03: Everyone needs to be considering the foreign entity of concern restrictions.
• 2:18
  SPEAKER_03: We do have some changes in credit timelines, and we do have some additional other restrictions and requirements on certain credits.
• 2:27
  SPEAKER_03: I'll talk through those in a minute, but the headline is the credits are around, but taxpayers and their representatives have to be thinking about how to comply.
• 2:37
  SPEAKER_03: So the largest new requirement is the foreign any of concern restrictions or fiak.
• 2:43
  SPEAKER_03: These rules are meant to reduce the influence of certain nations and the supply chain for the U.S.
• 2:48
  SPEAKER_03: energy industry.
• 2:49
  SPEAKER_03: This was a big source of political focus during the discussions of OB3.
• 2:55
  SPEAKER_03: And this is something that, you know, I think people in the industry are both struggling with how to comply with and also looking at it as potentially similar to the prevailing wage and apprenticeship rules, as this might be something that becomes built into the law, because I don't think either party going forward is necessarily going to want to say that domestic supply chain is not a priority, or that we're, you know, the concern about China producing a majority of components needed for the US energy industry is a good thing.
• 3:24
  SPEAKER_03: So stepping, stepping back, um, more detail on the fiak restrictions, it's very detailed.
• 3:30
  SPEAKER_03: It's made of three tests.
• 3:32
  SPEAKER_03: One measures ownership, another measures effective control of a taxpayer or its counterparty in certain transactions.
• 3:39
  SPEAKER_03: And the third um tests material assistance, which is essentially a supply chain exercise.
• 3:45
  SPEAKER_03: So starting at the top, there's the first test is for the prohibited foreign entity, and that's looking at whether the taxpayer that's going to be claiming the credit, whether they're the one actually doing the incentive activity or they are transferred a credit by that taxpayer, what their ownership is.
• 4:02
  SPEAKER_03: And generally what this rule is is looking at is are the entities owned or controlled by covered nations?
• 4:08
  SPEAKER_03: And those nations are China, Russia, North Korea, or Iran.
• 4:12
  SPEAKER_03: So entities, it also includes entities on certain U.S.
• 4:15
  SPEAKER_03: government watch lists.
• 4:16
  SPEAKER_03: Um, for instance, the Forsweeger Labor Migration Act is part of the concern, and nations that nations or entities that were on that watch list are also considered a prohibited foreign entity.
• 4:28
  SPEAKER_03: Um it also looks at entities majority controlled by the nations I mentioned or their citizens.
• 4:34
  SPEAKER_03: It's effective for tax years beginning after enactment of OB3, and it really requires taxpayers to analyze the ownership structures within their own organizations.
• 4:43
  SPEAKER_03: Um, and it prevents, as I mentioned, a taxpayer from transferring a credit to an SFE, even if that taxpayer doesn't have any prohibited foreign entity ownership.
• 4:52
  SPEAKER_03: The second big test is called the foreign influenced entity test.
• 4:55
  SPEAKER_03: As I mentioned, it's related to effective control of a taxpayer or a taxpayer that's going to be transferred the credit.
• 5:02
  SPEAKER_03: Um, and it's the entities that are considered are measured under as having significant control or influence by a specified foreign entity based on several factors.
• 5:12
  SPEAKER_03: One being control, one being ownership, and another being debt.
• 5:17
  SPEAKER_03: The application of this rule varies a bit by energy credit, but the highlight here is that taxpayers need to analyze contracts, agreements, and other arrangements entered into after the enactment of OB3, July 4th, 2025, for payments generally to a specified foreign entity, for sources of components for their projects, for production operations, for IP royalties, or other types of payments beyond 10 years, and for control or long-term service agreements.
• 5:44
  SPEAKER_03: So as you can see, that's a very broad range of activities that the rules are really trying to have taxpayers trace and be aware of as they enter into transactions, and even if they've continued transactions that they've, you know, started to some degree to plan for before enactment of OB3.
• 6:02
  SPEAKER_03: Um, the third test is, I think, perhaps the most onerous, even though the second is starting to sound difficult.
• 6:07
  SPEAKER_03: So the third is the material assistance test, and it's looking at whether a facility or component otherwise eligible for an energy credit would not be because a prohibited foreign entity has provided material assistance.
• 6:20
  SPEAKER_03: So for facilities otherwise eligible for the credit, this test is made is ensuring that the facility, if the facility has any material, includes any material assistance for a prohibited foreign entity, it would not be eligible for a credit.
• 6:34
  SPEAKER_03: And this is applicable for facilities on which construction begins after December 31st, 2025.
• 6:41
  SPEAKER_03: Um, and for other credits like 45x that are measured on a component basis.
• 6:45
  SPEAKER_03: The component, if a component is otherwise eligible for credit, it would not be credit eligible if the component includes any material assistance from a prohibited foreign entity.
• 6:55
  SPEAKER_03: And this is effective for tax years beginning after July 4th, 2025.
• 7:00
  SPEAKER_03: So as I was going through the third test, uh the material assistance test, what I hadn't done is actually sort of explain what material assistance is.
• 7:10
  SPEAKER_03: And it's a way for the statute to require that um taxpayers compute a material assistance cost ratio.
• 7:16
  SPEAKER_03: So it's looking at the relative costs of the taxpayer paid to a specified foreign entity relative to the total project cost.
• 7:26
  SPEAKER_03: Um the ratios are statutory and they do um the permitted amount that can be included every year decreases starting in 2026.
• 7:36
  SPEAKER_03: And then the statute did something unusual, and it said Treasury and the IRS are actually expected to issue safe harbors for this provision by 2027.
• 7:45
  SPEAKER_03: So in the interim, we see our clients and a significant part of the energy industry struggling to wrap their minds around fiak restrictions, as we are, and planning a compliance path forward.
• 7:57
  SPEAKER_03: So, in summary, uh the fiak provisions are complicated and difficult.
• 8:03
  SPEAKER_03: Um, I I I sort of feel like in this area, um, it's a little bit like the reaction we saw with industry when the prevailing wage requirements came out after IRA, which is sort of shock and awe that they would industry really would have to grapple with these rules.
• 8:17
  SPEAKER_03: And, you know, four years later, we see industry really wrapping their minds around it, have compliance systems that work.
• 8:24
  SPEAKER_03: Um, and there's just been a shift.
• 8:26
  SPEAKER_03: And over time, as the compliance systems get better and more efficient, the costs go down.
• 8:31
  SPEAKER_03: So the big thing to notice is to note here is that as we go forward, um the fiak provisions are going to be, to the extent energy tax will be a focus in this administration at all, it will probably be on the fiak restrictions.
• 8:44
  SPEAKER_03: We expect to see uh a full reg process on this.
• 8:48
  SPEAKER_03: Um, and I think the political interest will remain because the restrictions are, again, are focused at limiting foreign influence in our market and limiting US reliance on Chinese manufactured equipment.
• 9:00
  SPEAKER_03: So it may take time for US developers and the domestic supply chain to fill in that part of the market, but I think that's what we're looking at.
• 9:08
  SPEAKER_03: And the fact that credits like 45X, which are for the manufacture of those components, it's still on the books, is very important for the industry to adjust.
• 9:17
  SPEAKER_01: Yeah, those rules sound complex and difficult to understand.
• 9:20
  SPEAKER_01: And also a detailed knowledge of your supply chain and where all the components are coming from and understanding of your ownership structure.
• 9:27
  SPEAKER_01: So maybe if we we shift beyond the fiok, what other changes did OB3 make to the tax credits themselves?
• 9:35
  SPEAKER_03: So there are several credits that were sort of modified in positive ways for taxpayers.
• 9:40
  SPEAKER_03: Uh, and one of them was the credit for carbon capture and sequestration.
• 9:44
  SPEAKER_03: It was modified to provide the same credit amount for all end uses, which is a shift.
• 9:49
  SPEAKER_03: Previously, storage was worth the credit for storage was worth much more than a credit for a taxpayer that would use carbon captured in an enhanced oil recovery project to recover oil and gas.
• 10:01
  SPEAKER_03: Now those credit amounts are the same.
• 10:03
  SPEAKER_03: So I think we can see that it's a big benefit for industry to have a revenue stream with EOR projects and also be able to get a credit on the same sort of process.
• 10:12
  SPEAKER_03: Um, the other big winner in the OB3 for energy credits was the credit for clean fuel production, which was extended by two years and expanded.
• 10:21
  SPEAKER_03: It also has some other technical sort of restrictions that were added, but they really, I'm hopeful, um, actually make it this credit more workable for industry.
• 10:31
  SPEAKER_03: This credit was a little unusual that it effectively Congress took a bunch of other credits on the income tax and excise tax sides and merged them into one based on um the carbon intensity score of the underlying fuel.
• 10:45
  SPEAKER_03: So very complicated, meant to be less complicated over time, but it would probably take us a little bit to to fully uh have industry and and everyone else catch up.
• 10:55
  SPEAKER_03: Right.
• 10:56
  SPEAKER_01: Well it seems positive that it did expand the opportunities for carbon capture and clean fuels, but I guess it's not all positive news.
• 11:04
  SPEAKER_01: Some of the credits are actually ending earlier than they were initially expected, uh, creating some new pressures for developers.
• 11:12
  SPEAKER_01: So which of the credits are are we seeing end early under OB3?
• 11:16
  SPEAKER_03: That's a good question.
• 11:17
  SPEAKER_03: Well, first, we saw a lot of credits that received some political attention uh end within months of OB3 passing, namely the EV the credits for EVs and EV refueling property, um, credits for home and building energy efficiency provisions, and also some of the individual credits for energy efficiency.
• 11:36
  SPEAKER_03: Those are are all ending, I think, by the end of 2025.
• 11:40
  SPEAKER_03: We saw the credit for clean hydrogen production and two years earlier, which I think was a bit surprising to folks, but um, you know, more to be seen on that one.
• 11:49
  SPEAKER_03: Uh the big headline, though, was that the credit for clean energy credits is terminated for wind and solar facilities placed in service after 2027, unless construction begins within a year of enactment of OB3.
• 12:01
  SPEAKER_03: This is really unusual because the clean electricity credits are technology neutral.
• 12:06
  SPEAKER_03: The statute literally does not say what kind of facilities will qualify.
• 12:10
  SPEAKER_03: So by doing this, Congress has gone in and changed the statute to specifically point out wind and solar for a less favorable credit period.
• 12:19
  SPEAKER_03: And in fact, the statute leaves the rest of the every other type of facility that would be eligible for the credit to have a credit period that goes until 2034 and only then phases down.
• 12:32
  SPEAKER_03: So it's very unusual, but it's consistent with the political messaging around OB3 that the administration was particularly concerned about sources of energy, electricity that they said were intermittent and less reliable, and thus really the focus was on wind and solar.
• 12:48
  SPEAKER_01: A lot of these provisions sound very sweeping, but some things did stay the same as well.
• 12:52
  SPEAKER_01: What should companies know about what hasn't changed and where they still might find value?
• 12:57
  SPEAKER_03: So importantly, the prevailing wage and apprenticeship requirements continue to apply for most credits.
• 13:02
  SPEAKER_03: I think this has been good because taxpayers, as I mentioned before, have already dealt with a complex uh compliance process for that bonus.
• 13:10
  SPEAKER_03: And in a lot of cases, they can, you know, use some of the systems built in for other business purposes.
• 13:16
  SPEAKER_03: The bonus credit amounts uh also remain applicable, those bonuses being for domestic content and energy communities.
• 13:23
  SPEAKER_03: Domestic content also required a tremendous amount of compliance to take that incentive.
• 13:29
  SPEAKER_03: And we're finding that that information and a lot of those processes can be useful for taxpayers attempting to comply with the fiak restrictions.
• 13:37
  SPEAKER_03: So that is a good um development.
• 13:39
  SPEAKER_03: Uh, credit transferability also remains viable for most energy tax credits, which is a tremendous benefit and something that, you know, those of us who are watching OB3 go through deliberation in Congress, we were not expecting to be the outcome.
• 13:53
  SPEAKER_03: And the House bill that came out, credit transferability was greatly restricted, and that credit market was definitely in distress.
• 14:02
  SPEAKER_03: So we were really pleased to see it kept at the end.
• 14:04
  SPEAKER_03: That's great.
• 14:05
  SPEAKER_01: Well, Jennifer, we've also heard that there was an executive order that came out over the summer that's added some additional uncertainty as well.
• 14:13
  SPEAKER_01: So, what can you tell us about this executive order and what impact it might have on the energy industry?
• 14:18
  SPEAKER_03: Sure.
• 14:19
  SPEAKER_03: So um OB3 was passed on July 4th, and then on July 7th, the administration released an executive order focused on the wind and solar industry and only for the clean electricity credits, which was very unusual.
• 14:33
  SPEAKER_03: And it directed Treasury to take action within 45 days of enactment of OB3, which was August 18th, to strictly enforce the termination of the clean electricity credits for wind and solar facilities.
• 14:45
  SPEAKER_03: It also specifically directed Treasury to issue new and revised guidance as appropriate and consistent with applicable law to ensure that policies concerning the beginning of construction are not circumvented.
• 14:57
  SPEAKER_03: This was very unusual in a lot of ways.
• 14:59
  SPEAKER_03: I don't think we've seen another EO that was that specific telling an agency to do something very specifically and how to do it and what to focus on in a certain amount of time.
• 15:10
  SPEAKER_03: The EO also directed Treasury to take prompt action as appropriate and consistent with applicable law to implement the enhanced fiak restrictions by the same date, August 18th.
• 15:20
  SPEAKER_03: So, you know, between July 7th and August 15th, when we did see Treasury action, this caused a tremendous amount of anxiety for the wind and solar industry.
• 15:31
  SPEAKER_03: And in fact, the whole energy industry was sort of on edge looking to see if something would come out of the administration on the fiak restrictions.
• 15:38
  SPEAKER_03: So, you know, a lot of discussion of the beginning of construction rules, a lot of fearful rumors about changes to those rules that could have happened.
• 15:46
  SPEAKER_03: Um and I think to a large degree this led to sort of a pause in project development, at least for that 45-day period, which is even more troubling because wind and solar really needs to begin construction on their facilities within the next year.
• 15:59
  SPEAKER_03: So it was a lot of um concerning messaging and a fearful time until August 15th, when Treasury and IRS exceeded expectations and released notice 2025-42.
• 16:13
  SPEAKER_03: This notice is extremely well written.
• 16:15
  SPEAKER_03: It was very thorough.
• 16:16
  SPEAKER_03: I think industry, you know, has had some, you know, not everyone is thrilled.
• 16:21
  SPEAKER_03: I personally am relieved.
• 16:22
  SPEAKER_03: I think it could have been much harsher than it was.
• 16:25
  SPEAKER_03: Um and the first thing was it's effective September 2nd, 2025.
• 16:30
  SPEAKER_03: During the 45, 43 days of anxiety, um, we had discussions about would the guidance coming out of Treasury be retroactively applicable?
• 16:40
  SPEAKER_03: Would it go back to the enactment of OB3?
• 16:43
  SPEAKER_03: Would the IR would the industry be sort of caught wrong footed on their transactions?
• 16:48
  SPEAKER_03: And um, Treasury did a really thoughtful thing not making this retroactively effective.
• 16:53
  SPEAKER_03: Um and to understand the notice, it's helpful to remember that planned phase outs of the energy credit, you know, aren't new.
• 16:59
  SPEAKER_03: And there have been a lot of guidance on how to meet those prior deadlines, primarily in other notices published by the IRS similar to this one.
• 17:07
  SPEAKER_03: Um, to be eligible for credits, traditionally a taxpayer had to begin construction on a facility by meeting either a 5% safe harbor or a physical work test before a cutoff date.
• 17:17
  SPEAKER_03: And the cutoff dates were generally statutory.
• 17:20
  SPEAKER_03: Um, back when the energy credits were only renewed for two or three years at a time, we would see at the end of the year energy tax attorneys like myself never went to holiday parties because we were always waiting for the extender bills to come out.
• 17:34
  SPEAKER_03: If we had all of our clients running around, you know, anxiously looking to see if they would get another year of eligibility.
• 17:40
  SPEAKER_03: Um, so anyway, for both tests, both the 5% safe harbor or the physical work test, the taxpayer was also required to meet a continuity requirement.
• 17:49
  SPEAKER_03: And it could either be met by placing the project in service by the end of a continuity safe harbor, which was provided by IRS guidance in the form of other beginning of construction notices.
• 17:59
  SPEAKER_03: There are about 11 of them.
• 18:02
  SPEAKER_03: Um, or a taxpayer could complete the project using continuous construction or the continuous efforts tests, which are a facts and circumstances to termination, but they would allow a taxpayer to go beyond the continuity safe harbor, which was generally four years.
• 18:17
  SPEAKER_03: Um the continuity efforts test included more types of activities, including continuous construction.
• 18:22
  SPEAKER_03: It was broader.
• 18:24
  SPEAKER_03: And during COVID, those two tests, continuous construction and continuous efforts, were largely merged because we had such significant supply change delays.
• 18:33
  SPEAKER_03: Right.
• 18:33
  SPEAKER_03: So in order to have more projects actually go forward, that was done by notice.
• 18:39
  SPEAKER_03: And so this notice changes some of those underlying rules, but the fundamental structure of the beginning of construction rules remain the same.
• 18:46
  SPEAKER_03: The biggest change is that the 5% safe harbor is no longer available for wind and solar facilities, except for residential and community solar facilities and other facilities, limited number of facilities that have low output under 1.5 megawatts AC.
• 19:02
  SPEAKER_03: However, the physical work test remains.
• 19:06
  SPEAKER_03: Similarly, the continuous efforts test, which was broader, uh, is no longer available, but the continuous construction test remains available.
• 19:14
  SPEAKER_03: So, most importantly, the four-year continuity safe harbor is retained for wind and solar facilities.
• 19:19
  SPEAKER_03: During the deliberations at Treasury, we heard there was a lot of back and forth.
• 19:23
  SPEAKER_03: At one point, there wasn't going to be a safe harbor.
• 19:26
  SPEAKER_03: This was, you know, DC's kind of a small place.
• 19:29
  SPEAKER_03: We had, you know, everyone was getting in on the action.
• 19:32
  SPEAKER_03: Senator Grassley was very upset, apparently, about we heard uh about what was going on at Treasury behind the scenes with this notice, and he put a hold.
• 19:42
  SPEAKER_03: He and Senator Curtis put a hold on some Treasury nominees and reaction.
• 19:47
  SPEAKER_03: So after at the end of the day, um, you know, the BOC rules provided in IRS notices remain large of the same, and where they don't, you know, thankfully notice 2025-42, you know, is very explicit about it.
• 20:01
  SPEAKER_03: There's one small change that I'd like to mention, which is uh we did get a little bit more clarity about the inventory rule for the physical work test.
• 20:09
  SPEAKER_03: Again, you know, somewhat minor, but important to watch.
• 20:13
  SPEAKER_03: I think the important thing to note is that the folks at IRS Chief Council who draft these notices are very thoughtful.
• 20:20
  SPEAKER_03: They know the market, they know how much the market relies on these rules.
• 20:23
  SPEAKER_03: And so they tried to be very explicit where there was a change.
• 20:26
  SPEAKER_03: Um, so I'm really grateful for that.
• 20:28
  SPEAKER_03: And I think industry appears to be pretty relieved that the, you know, the notice did not further damage the beginning of construction rules.
• 20:35
  SPEAKER_03: I do think it it particularly hurt certain segments.
• 20:39
  SPEAKER_03: Um, you know, offshore wind had a special uh continuity safe harbor of 10 years.
• 20:44
  SPEAKER_03: So this really sort of cuts the knees out from their projects.
• 20:47
  SPEAKER_03: They are are rarely able to sort of get anything done earlier.
• 20:52
  SPEAKER_03: They have a ton of permitting issues, so we'll be watching that industry closely.
• 20:56
  SPEAKER_01: Okay.
• 20:57
  SPEAKER_01: Well, a lot of moving parts, a lot of things to keep track of.
• 21:00
  SPEAKER_01: With all this in motion, what are some of the key takeaways or immediate actions companies in the energy tax market should be considering over the next couple months?
• 21:10
  SPEAKER_03: So industry, as I mentioned, is generally relieved.
• 21:13
  SPEAKER_03: Um, but I think they've already been making the shift to the physical work test over time.
• 21:18
  SPEAKER_03: Utility scale developers and their financing counterparts have had long familiarity with it and may actually find it less subjective than the 5% safe harbor due to significant cost fluctuations in the market.
• 21:29
  SPEAKER_03: As we know, inflation is an issue across the board and now facing tariffs on certain products that could go into these facilities.
• 21:37
  SPEAKER_03: Um, I think some folks before this notice and before the last couple of years have been, you know, using the physical work test as actually a more concrete solution.
• 21:47
  SPEAKER_03: Um I just wanted to note that reporting from the Financial Times suggests that OB3 has led to about 19 billion in projects being canceled.
• 21:54
  SPEAKER_03: And there have been investment announcements, you know, have been have been down 20%.
• 22:00
  SPEAKER_03: But at the same time, analysts and, you know, market analysts have estimated that the sector will rebound and eventually see more new installed capacity than today.
• 22:08
  SPEAKER_03: And we sort of saw that play out after this notice was released because within a day, the stock prices of the largest um solar manufacturers went up remarkably.
• 22:18
  SPEAKER_03: So I think we see that this industry is actually quite flexible and adaptable.
• 22:24
  SPEAKER_03: And we're telling our clients, you know, sort of some key things.
• 22:27
  SPEAKER_03: Um, you know, obviously wind and solar has a year to begin construction.
• 22:31
  SPEAKER_03: The rest of the types of facilities that are um that are eligible for the clean electricity credits have longer, but we're definitely telling folks to accelerate planned investments in renewables to maximize credit opportunities, including credit transferability.
• 22:45
  SPEAKER_03: Um we're talking to folks about carbon capture.
• 22:49
  SPEAKER_03: It's it's a technology that's, you know, the incentives been out there since 2008, but it had never been sort of economically viable and scalable.
• 22:56
  SPEAKER_03: And we're seeing we're seeing the market move towards a more scalable adoption.
• 23:00
  SPEAKER_03: So there are there are some opportunities there, and the 45-2 credit is now more lucrative.
• 23:05
  SPEAKER_03: Um, if you're in a business where clean fuel credit, where the clean fuel credit is relevant, consider the how the longer time frame may affect investments.
• 23:13
  SPEAKER_03: Um, we're telling people to stay focused on prevailing wage compliance, it's not going away.
• 23:18
  SPEAKER_03: And similarly, to watch for anticipated fiat guidance and to think about fiat compliance.
• 23:24
  SPEAKER_01: Well, great.
• 23:24
  SPEAKER_01: Well, thank you so much for joining me today, Jennifer.
• 23:26
  SPEAKER_01: This has been a great conversation.
• 23:28
  SPEAKER_01: Thanks, Diana.
• 23:30
  SPEAKER_02: That's our show for today.
• 23:32
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• 23:52
  SPEAKER_02: From Thought Leadership at PWC, I'm Heather Horn.
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  SPEAKER_00: This podcast is for general information purposes only and should not be used as a substitute for consultation with professional advisors, including accountants and lawyers.