# Prop. Treas. Reg. § 1.25C-3: Special rules.

Proposed regulation, not in force. REG-118264-23, 89 FR 85099, published 2024-10-25 <https://www.federalregister.gov/documents/2024/10/25/2024-24110/energy-efficient-home-improvement-credit>. Interprets 26 U.S.C. § 25C.

Par. 2. Sections 1.25C-0 through 1.25C-4 are added to read as follows:

(a) In general. This section provides special rules regarding the section 25C credit. Except as otherwise provided in this section, the other rules of the section 25C regulations continue to apply.

(b) Enabling property; Taxable year of installation —(1) In general. Except as provided in paragraph (b)(2) of this section, enabling property is considered to have been installed in conjunction with enabled property if it was installed in the same taxable year as the enabled property was installed.

(2) Safe harbor. If enabling property and enabled property are installed in consecutive taxable years, the taxpayer may treat the enabling property and enabled property as installed in the same taxable year (deemed taxable year), provided that the deemed taxable year is the later of the taxable year in which the enabling property was installed or the enabled property was installed. Nothing in this paragraph (b)(2) negates the requirement to provide a PIN for both the enabling and enabled property as required in section 25C(h), § 1.25C-4(a), or guidance.

(3) Example. In taxable year 2024, Taxpayer C installs a new panelboard in his principal residence, and in taxable year 2025, C installs a new electric heat pump water heater in his principal residence. If C chooses to apply the safe harbor under paragraph (b)(2) of this section, C may treat both the enabling property (panelboard) and the enabled property (electric heat pump water heater) to have been installed in taxable year 2025, for purposes of the section 25C credit. If C chooses not to apply the safe harbor under paragraph (b)(2) of this section, then the panelboard is determined to have been installed in taxable year 2024, and the electric heat pump water heater is determined to have been installed in taxable year 2025, for purposes of the section 25C credit. Thus, if C chooses not to apply the safe harbor under paragraph (b)(2) of this section, then C cannot claim the section 25C credit with respect to the panelboard.

(c) Applicability date. This section applies to taxable years ending after [DATE OF PUBLICATION OF FINAL REGULATIONS IN THE FEDERAL REGISTER ].