How an investment grade seller unlocked the IG premium for ITCs
Case Study
§48 ITC
Q1 2025
Reunion guided a Fortune 500 energy company's first tax credit sale to close in 45 days at the premium end of the ITC market.
Overview
A Fortune 500 energy company with an investment grade (IG) credit rating came to Reunion with $45M in §48 ITCs and a clear goal: maximize cash proceeds without a drawn-out process.
Reunion had market intelligence which suggested that an investment grade seller could command a premium in the market if matched with the right buyer — and we ran a process that delivered.
$0.95
Gross price
3 Days
To agree on key terms
Reunion Market Monitor
See the real-time tax credit transfer pricing, terms, and market intelligence that helped this seller close.
Market intelligence
A first-time seller with a clear goal
The deal
§48 ITC
2025
$40–50M
§48 Investment tax credits
Utility-scale battery storage
Deal structure
An investment-grade §48 ITC transfer structured around a single high-capacity counterparty.
The seller
- Fortune 500 energy company
- Over $100B in annual revenue
- Publicly traded
- Investment grade credit rating
- First tax credit transfer
The seller’s objectives
- Maximize cash proceeds
- Close with a single counterparty who could take $40M+ of tax credits
- Minimize execution timeline and risk
Sourcing the ideal buyer from a vetted pool
How Reunion's market intelligence identified the right match at a premium price from a pool of 50+ vetted buyers.
Reunion Market Monitor revealed key insights about IG tax credits and pricing:
- ~20% of dollarized demand across Reunion's vetted buyer pool requires an IG counterparty
- Nearly 60% of transaction-ready buyers are willing to pay $0.02+ premium for IG tax credits, regardless of credit type, technology, or volume
As such, Reunion ran a buyer discovery process based on:
- Investment grade focus: Buyers who specifically required an investment grade seller
- Fiscal-year filers: Buyers with a March fiscal-year close, often overlooked by other sellers because they were “out of market” relative to the calendar-year cycle
The result
A 130-year-old American company ($2B+ annual revenue, fiscal-year filer) was identified as the ideal counterparty and met the seller’s $0.95 ask.
See the real-time tax credit transfer data that helped source the right buyer.
Orchestrating a 45-day transaction close
How Reunion aligned terms early and prepared the parties to move fast.
Aligned early on critical terms
Pricing
Positioned $0.95 as a market-clearing price upfront to buyers to avoid a protracted bidding process
Tax credit insurance
Identified a buyer willing to forego insurance per the seller’s desire, accepting the IG parent company's indemnification instead
Volume contingency
Agreed upfront on a deal structure that included pricing tiers outside the $40M–$50M target range, so the cost segregation report wouldn't trigger renegotiation
Ensured buyer transaction-readiness
- Ran a tax credit workshop with internal stakeholders
- Confirmed CFO had agreed to terms and delegated signing authority to VP of Tax
- Confirmed Treasury had $60M cash on standby
- Verified advisors were lined up: primary and backup law firms identified, two Big 4 firms engaged for diligence
3 Days
To align on key commercial terms
7 Days
From term sheet to diligence memo
45 Days
From term sheet to close
