It sounds like an automobile manufacturer in America (like GM) can extend some, or all, of their tax credits to Sunrise in Australia, for direct payment. You need to be a Philadelphia lawyer to understand all of this jargon, but it sounds like there will be an avenue to money for Sunrise directly in Australia. We will likely need to wait for the middle of the year to know for sure.

Tax Credit Transferability and Direct Pay Proposed Under the IRA
Potential for interactions with Section 174 complicate a seemingly simple program

https://taxexecutive.org/tax-credit-transferability-and-direct-pay-proposed-under-the-ira/