overed “repair” (among other definitions)?What accounts or records will be deemed to be “sufficient”?How will the prevailing wage and apprenticeship requirements be enforced?How will the narrow “good-faith efforts” exception to the apprenticeship requirement be applied in practice?How will inevitable fluctuations in the percentages of “total work hours” performed by apprentices be managed among taxpayers, contractors, and subcontractors over the life of covered projects?Will the Treasury Department be subject to legal challenge for attempting to implement the tax credit requirements without providing any meaningful guidance on these and other issues?How much will the new requirements increase project construction costs and reduce the pool of contractors and subcontractors willing to accept the risks imposed by the new labor requirements?We will provide updates if and when the Treasury Department clarifies these issues in additional regulations or guidance.Footnotes1IRS Notice 2022-61, 87 Fed. Reg. 73580 (Nov. 30, 2022). The Treasury guidance further links to new FAQs posted by the US Department of Labor for “background purposes only.” SeePrevailing Wage and the Inflation Reduction Act | U.S. Department of Labor (dol.gov)andInflation Reduction Act Apprenticeship Resources | Apprenticeship.gov.