Monthly Market Digest - October 2025

The rush to close out 2024 tax credits is finally coming to an end, with the October 15 tax filing deadline approaching. Read on for highlights on what the Reunion team has been seeing in the tax credit market, along with recent deal highlights.

What we’re seeing in the market:

More buyers are looking to delay payments for 2025 credits until 2026

• Due to the OBBBA, some corporations overpaid their estimated quarterly taxes relative to what they will end up owing for 2025. Therefore, they prefer delaying payments for tax credits until 2026, because they do not anticipate realizing the benefit of the credits until April 15, 2026
• We have observed more buyers looking to pursue carrybacks to offset prior year taxes; carryback buyers typically seek delayed payment terms, given uncertainty around when they will receive tax refunds from the IRS
• In general, we have seen an increasing share of transactions occurring well into the following calendar year, and expect this seasonal trend to continue. For example, Reunion closed approximately 15 transactions for the 2024 tax year, totaling over $550M in credit volume, in the weeks leading up to October 15, 2025

Sellers are showing flexibility in pricing for investment-grade buyers that are willing to forward commit to ITCs that will be generated in 2026 or 2027

• Sellers are unable to get high advance rates from lenders for tax credit transfer bridge loans without a committed buyer. The net advance rate is typically <70% of the face value of the tax credits
• Sellers are showing flexibility in pricing to secure commitments from investment-grade buyers to purchase credits generated in 2026 or 2027
• Reunion has also partnered with a major financial institution to offer forward ITC and 45X commitments for 2026 or 2027 credits with at least $50M in volume; please contact us for pricing and further details

Buyers are demanding §45U credits, and pricing remains high

• A number of large Reunion clients are focused specifically on identifying §45U credits, which are production-based credits generated by nuclear power facilities. Buyers are drawn to the relatively straightforward diligence process, lack of §50 recapture risk, and the current administration’s general support of nuclear power
• Spot 2025 pricing for credits remains elevated due to the fairly small universe of §45U credit sellers; as with other credits, buyers willing to enter into a multi-year agreement can achieve a 1 to 2.5 cent discount on pricing, depending on the length of commitment

Highlights from Recently Closed Transactions

Project Wind River | $150M+ in §45U nuclear credits transacted on a very short closing timeline due to high demand

Credit type: §45U

Overview: Reunion brought two highly motivated, publicly traded companies together to transact on §45U nuclear credits, going from a signed term sheet to closing in two weeks.

Highlights: Looming deadlines meant both buyer and seller needed to lean on legal and advisory resources, including Reunion, to negotiate terms and move quickly through due diligence and approvals.

Project Ginkgo | $75M+ in §48 credits from battery storage project with deferred payment schedule

Credit type: §48

Overview: Reunion worked with a repeat client to sell tax credits from a battery storage project to a publicly-traded buyer.

Highlights:The purchaser was able to offer a premium price in exchange for deferred payment, which was attractive given the seller’s access to low-cost capital. Resulting payment will take place over a year after the project was placed in service.

Reunion's Compliance Software: Tracking Prevailing Wage and Apprenticeship compliance for a large solar developer

Credit type: §48E

Overview: Reunion is under contract with a major solar developer to manage PWA compliance for their entire 2025-2026 portfolio. Reunion's report is a key piece of documentation for the developer's tax equity partner, which is a leading bank.

Highlights: The tax equity partner will receive frequent and thorough PWA updates via Reunion's software throughout the construction and O&M phases. It was critical for the tax equity partner to gain comfort with Reunion's PWA compliance process prior to closing the transaction.

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