S.J. Res. 107 (119th)Bill Overview

For congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to "Beginning of Construction Requirements for Purposes of…

Energy|Energy
Cosponsors
Support
Democratic
Introduced
Feb 12, 2026
Discussions
Bill Text
Current stageCommittee

Placed on Senate Legislative Calendar under General Orders. Calendar No. 363.

Introduced
Committee
Floor
President
Law
Congressional Activities
01 · The brief

This joint resolution, under the Congressional Review Act, disapproves and nullifies an IRS rule (Notice 2025–42) that sets "beginning of construction" requirements affecting when certain wind and solar facilities lose eligibility for clean electricity production and investment tax credits.

If enacted, the resolution would strip the IRS rule of legal effect and prevent its implementation.

Passage25/100

Narrow administrative target improves prospects, but topic is politically charged and final enactment hinges on both chambers plus presidential approval.

CredibilityAligned

Relative to its intended legislative type, this bill is a concise and legally focused Congressional Review Act resolution that clearly accomplishes the single objective of disapproving a specified IRS rule. It relies on the existing CRA statutory framework rather than restating procedural details.

Contention72/100

Progressives emphasize climate and deployment impacts from nullification.

02 · What it does

Who stands to gain, and who may push back.

Who this appears to help vs burden50% / 50%
DevelopersPermitting process · Federal agencies
Likely helped
  • Targeted stakeholdersPreserves existing tax-credit eligibility for wind and solar projects that the IRS rule might have curtailed.
  • DevelopersReduces near-term compliance and paperwork burdens on developers who would have followed the new IRS requirement.
  • Targeted stakeholdersProtects investments and construction jobs tied to projects relying on established credit eligibility expectations.
Likely burdened
  • Targeted stakeholdersConstrains the IRS's ability to interpret and implement statutory tax provisions administratively.
  • Permitting processMay preserve gaps or loopholes the IRS aimed to address, permitting extended or disputed credit claims.
  • Federal agenciesCould increase federal revenue costs if the rule would have narrowed credit eligibility and is now blocked.
03 · Why people split

Why the argument around this bill splits.

Progressives emphasize climate and deployment impacts from nullification.
Progressive10%

Likely strongly opposed.

Progressives generally support tax credits for renewables and view the IRS rule as enabling continued deployment and climate progress.

Nullifying the rule is seen as undermining decarbonization and clean energy jobs.

Likely resistant
Centrist50%

Mixed view.

Appreciates congressional oversight of agencies but worries nullifying may disrupt energy investment and legal certainty.

Will weigh fiscal impacts, statutory intent, and administrative procedure before deciding.

Split reaction
Conservative85%

Likely supportive.

Conservatives often argue the IRS exceeded authority and the tax credits should end per statute.

Disapproval is framed as restoring congressional intent and limiting administrative overreach.

Leans supportive
04 · Can it pass?

The path through Congress.

Introduced

Reached or meaningfully advanced

Committee

Reached or meaningfully advanced

Floor

Still ahead

President

Still ahead

Law

Still ahead

Passage likelihood25/100

Narrow administrative target improves prospects, but topic is politically charged and final enactment hinges on both chambers plus presidential approval.

Scope and complexity
24%
Scopenarrow
24%
Complexitylow
Why this could stall
  • Substantive details and effects of IRS Notice 2025–42 are not in the resolution text
  • Scale and source of lobbying from renewable and fossil-fuel stakeholders
05 · Recent votes

Recent votes on the bill.

06 · Go deeper

Go deeper than the headline read.

Included on this page

Progressives emphasize climate and deployment impacts from nullification.

Narrow administrative target improves prospects, but topic is politically charged and final enactment hinges on both chambers plus presiden…

Unlocked analysis

Relative to its intended legislative type, this bill is a concise and legally focused Congressional Review Act resolution that clearly accomplishes the single objective of disapproving a specified IRS rule. It relies on…

Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.

Perspective breakdownsPassage barriersLegislative design reviewStakeholder impact map
Open full analysis