In-Depth Look: Transferable Tax Credits Under the Inflation Reduction Act
The Inflation Reduction Act (IRA) created 11 transferable tax credits.
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Key features of the IRA's 11 transferable tax credits
The Inflation Reduction Act (IRA) created 11 transferable tax credits to promote investment into clean energy. This article summarizes key features of each transferable credit including technology, duration, period of availability, and rates. Depending on the credit, we included three rates:
- Base: Rate assuming prevailing wage and apprenticeship requirements are not met.
- Full: Rate assuming prevailing wage and apprenticeship requirements are met. The full rate is five times higher than the base rate.
- Bonus: Additional rates assuming bonus credits – energy community, domestic content, low-income community – are met.
Jump to a credit
To jump directly to a credit, click a link below:
- §45 PTC – Electricity produced from certain renewable sources
- §45Y PTC – Clean electricity production credit (technology-neutral PTC)
- §48 ITC – Energy credit
- §48E ITC – Clean electricity investment credit (technology-neutral ITC)
- §30C ITC – Alternative fuel vehicle refueling property credit
- §45U PTC – Zero-emission nuclear power production credit
- §45Q PTC – Credit for carbon oxide sequestration
- §45Z PTC – Clean fuel production tax credit
- §45V PTC – Clean hydrogen production tax credit
- §48C ITC – Advanced energy project credit
- §45X PTC – Advanced manufacturing production credit
§45 PTC - Electricity produced from certain renewable sources
Funding mechanism: Production tax credit
Technology grouping: Electricity
IRA Section: 13101
New or existing: Existing - modified and extended
Eligibility: Facilities generating electricity from wind, biomass, geothermal, solar, small irrigation, landfill and trash, hydropower, and marine and hydrokinetic renewable energy
U.S. Code: 26 U.S. Code §45
Duration: 10 years from the date the project is placed in service
Period of availability: Projects must begin construction prior to 1/1/2025. For projects placed in service in 2025 or later, the §45Y PTC will replace the §45 PTC
Stackability and limitations: Cannot be stacked with §48
Inflation adjustment: Subject to an annual inflation adjustment
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Not applicable
Rates
The §45 PTC has two different rate regimes depending on when a project was placed in service. If a project was placed in service before 1/1/2022, the full PTC calculation is [1.5 cents] x [inflation adjustment factor] rounded to the nearest 0.1 cents. Importantly, projects placed in service before 2022 are not subject to prevailing wage and apprenticeship requirements. If a project was placed in service after 12/31/2021, the full PTC rate calculation is [0.3 cents] x [inflation adjustment factor] rounded to the nearest 0.05 cents. For projects meeting PWA requirements, this product is multiplied by five.
- Base rate (placed in service before 1/1/22): Not applicable. Projects placed in service before 1/1/22 are not subject to prevailing wage and apprenticeship requirements. They receive the full rate
- Base Rate (placed in service after 1/31/21): $5.50 per MWh for wind, closed-loop biomass, geothermal, and solar. $3.00 per MWh for open-loop biomass, landfill gas, trash, qualified hydropower, and marine and hydrokinetic renewable energy
- Full rate: (placed in service before 1/1/22): $28.00 per MWh for wind, closed-loop biomass, and geothermal. $14.00 per MWh for open-loop biomass, landfill gas, trash, qualified hydropower, and marine and hydrokinetic renewable energy
- Full Rate (placed in service after 1/31/21): $27.50 per MWh for wind, closed-loop biomass, geothermal, and solar. $15.00 per MWh for open-loop biomass, landfill gas, trash, qualified hydropower, and marine and hydrokinetic renewable energy
- Energy Community: 10%
- Domestic Content: 10%
§45Y PTC - Clean electricity production credit
Funding mechanism: Production tax credit
Technology grouping: Electricity
IRA Section: 13701
New or existing: New
Eligibility: Technology-neutral tax credit for production of clean electricity. The §45Y PTC is for facilities generating electricity for which the greenhouse gas emissions rate is not greater than zero
U.S. Code: 26 U.S. Code §45Y
Duration: 10 years from the date the project is placed in service
Period of availability: Projects placed in service beginning in 2025 are eligible for the credit.
The credit is subject to a four-year phase-out (100%, 75%, 50%, 0%) for projects that begin construction in the first calendar year after the ”applicable year,” which is the later of (1) 2032 or (2) the calendar year in which the IRS determines that the annual greenhouse gas emissions from the production of electricity in the U.S. are equal to or less than 25% of the annual greenhouse gas emissions from the production of electricity in the U.S. in 2022.
Below is an example phase-out schedule, assuming the "applicable year" is 2032. An eligible project that begins construction in 2035 and meets PWA requirements will generate §45Y PTCs worth $13.75 per MWh when it is placed in service.
Stackability and limitations: Cannot be stacked with §48E or §45Q
Inflation adjustment: Subject to an annual inflation adjustment
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Not applicable
Rates
- Base rate: $5.50 per MWh (as increased by annual inflation adjustment factor from 2023)
- Full rate: $27.50 per MWh (as increased by annual inflation adjustment factor from 2023)
- Energy Community: 10%
- Domestic Content: 10%
Guidance: Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan
§48 ITC - Energy credit
Funding mechanism: Investment tax credit
Technology grouping: Electricity
IRA Section: 13102
New or existing: Existing - modified and extended
Eligibility: Fuel cell, solar, geothermal, small wind, energy storage, biogas, microgrid controllers, and combined heat and power properties
U.S. Code: 26 U.S. Code §48
Period of availability: Projects must begin construction prior to 1/1/2025. For projects placed in service in 2025 or later, the §48E ITC will replace the §48 ITC
Stackability and limitations:
- Cannot be stacked with §48E, §45, §45Y, §48C, §45Q
- Subject to recapture per §50
Inflation adjustment: None
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Subject to five-year recapture period beginning on placed-in-service date. Recapture amount decreases by 20% per year
Rates
- Base rate: 6%
- Full rate: 30%
- Energy Community: 10%
- Domestic Content: 10%
- Low-Income: 10% if located in low-income community or on Indian land. 20% if part of qualified low-income residential building project or qualified low-income economic benefit project. Limited to projects less than 5 MW
Guidance (since passage of the IRA):
- Notice of proposed rulemaking: Definition of Energy Property and Rules Applicable to the Energy Credit (11/22/2023)
- Final rule pending
§48E ITC - Clean electricity investment credit (technology-neutral ITC)
Funding mechanism: Investment tax credit
Technology grouping: Electricity
IRA Section: 13702
New or existing: New
Eligibility: Technology-neutral tax credit for investment in facilities generating electricity for which the greenhouse gas emissions rate is not greater than zero
U.S. Code: 26 U.S. Code §48E
Period of availability: Projects placed in service beginning in 2025 are eligible for the credit.
The credit is subject to a four-year phase-out (100%, 75%, 50%, 0%) for projects that begin construction in the first calendar year after the ”applicable year,” which is the later of (1) 2032 or (2) the calendar year in which the IRS determines that the annual greenhouse gas emissions from the production of electricity in the U.S. are equal to or less than 25% of the annual greenhouse gas emissions from the production of electricity in the U.S. in 2022.
Below is an example phase-out schedule, assuming the "applicable year" is 2032. An eligible project that begins construction in 2034 and meets PWA requirements will generate a §48E ITC worth 22.5% of the project’s qualified investment when it is placed in service
Stackability and limitations:
- Cannot be stacked with §48, §45, §45Y, §48C, §45Q
- Subject to recapture per §50
Inflation adjustment: None
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Subject to five-year recapture period beginning on placed-in-service date. Recapture amount decreases by 20% per year
Rates
- Base rate: 6%
- Full rate: 30%
- Energy Community: 10%
- Domestic Content: 10%
- Low-Income: 10% if located in low-income community or on Indian land. 20% if part of qualified low-income residential building project or qualified low-income economic benefit project. Limited to projects less than 5 MW
Guidance: Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan
§30C ITC – Alternative fuel vehicle refueling property credit
Funding mechanism: Investment tax credit
Technology grouping: Vehicles
IRA Section: 13404
New or existing: Existing - modified and extended
Eligibility: For clean-burning fuels, as defined in the statute. Alternative fuels include electricity (charging property), ethanol, natural gas, liquified petroleum gas, hydrogen, and biodiesel
U.S. Code: 26 U.S. Code §30C
Period of availability: Project must be placed in service between 1/1/2023 and 12/31/2032
Stackability and limitations:
- The project must be in the U.S. in a low-income or rural area
- The credit is capped at $100,000 per property
Inflation adjustment: None
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Recapture provision is anticipated in Treasury proposed regulations
Rates
- Base rate: 6%
- Full rate: 30%
Guidance (since passage of the IRA):
- Notice 2022-56: Request for comments on Section 45W and Section 30C (12/3/2022)
- Notice 2024-20 Guidance on Satisfying the Geographical Requirements of the Section 30C Alternative Fuel Vehicle Refueling Property Credit (1/19/2024)
- Notice 2024-20 - Appendix A List of 11-digit census tract GEOIDs that are eligible for § 30C using 2015 delineations of census tract boundaries (1/19/2024)
- Notice 2024-20 - Appendix B List of 11-digit census tract GEOIDs that are eligible for § 30C using 2020 delineations of census tract boundaries, including non-urban census tracts (1/19/2024)
- Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan. §30C was previously authorized under law, so existing guidance may still apply
§45U PTC – Zero-emission nuclear power production credit
Funding mechanism: Production tax credit
Technology grouping: Electricity
IRA Section: 13105
New or existing: New
Eligibility: Electricity from qualified nuclear power facilities
U.S. Code: 26 U.S. Code §45U
Duration: 2024-2032
Period of availability: Available for electricity produced and sold after 12/31/23, in tax years beginning after that date. Not available for tax years beginning after 12/31/32
Stackability and limitations:
- Cannot claim §45J credit
- Credit subject to “reduction amount” depending on the amount of energy produced and the gross receipts of the facility
- Payments from federal, state, or local zero-emission nuclear subsidies reduce the credit amount
Inflation adjustment: Subject to annual inflation adjustment
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Not applicable
Rates
- Base rate: $3.00 per MWh, subject to “reduction amount” depending on the amount of energy produced and the gross receipts of the facility
- Full rate: 15.00 per MWh, subject to “reduction amount” depending on the amount of energy produced and the gross receipts of the facility. Apprenticeship requirements do not apply to §45U to receive the full rate
Guidance: Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan
§45Q PTC - Credit for carbon oxide sequestration
Funding mechanism: Production tax credit
Technology grouping: Electricity
IRA Section: 13104
New or existing: Existing - extended and modified
Eligibility: The §45Q PTC is for carbon dioxide sequestration coupled with permitted end uses within the U.S.
U.S. Code: 26 U.S. Code §45Q
Duration: 12 years from the date facility is placed in service
Period of availability: Facilities must be placed in service before 2033
Stackability and limitations:
- Limited to U.S. facilities with minimum capture volumes:
- 1,000 metric tons of CO2 per year for direct air capture (DAC) facilities
- 18,750 metric tons for electricity-generating facilities with carbon capture capacity of 75% of baseline CO2 production
- 12,500 metric tons for any other facility
- Cannot be stacked with §45V, §45Z, §48, §48C, or §48E
Inflation adjustment: Subject to annual inflation adjustment
Elective pay (direct pay): Available to tax-exempt entities. Available to non-tax-exempt entities for up to five years. If a non-tax-exempt entity selects elective pay, such entity “shall be treated as having made such election for each of the four succeeding tax years.” During the five-year period, a non-taxexempt entity “may elect to revoke the application” of elective pay for the remainder of the five-year period. The non-taxexempt entity cannot “subsequently revoke” the elective pay revocation
Recapture: Subject to recapture if qualified carbon ceases to be captured, disposed of, or used as a tertiary injectant. Recapture period is three years, starting from first injection for disposal in secure geological storage or use as a tertiary injectant. Any recapture amount will be accounted for in the tax year that it’s identified and reported
Rates
- Base rate: $17/metric ton of carbon dioxide captured and sequestered ($36 for DAC facilities). $12/metric ton for carbon dioxide that is injected for enhanced oil recovery or utilized ($26 for DAC facilities)
- Full rate: $85/metric ton of carbon dioxide captured and sequestered ($180 for DAC facilities). $60/metric ton for carbon dioxide that is injected for enhanced oil recovery or utilized ($130 for DAC facilities)
Guidance (since passage of the IRA):
- Notice 2022-57: Request for comments on the Credit for Carbon Oxide Sequestration (11/3/2022)
- Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan
§45Z PTC – Clean fuel production tax credit
Funding mechanism: Production tax credit
Technology grouping: Fuels
IRA Section: 13204
New or existing: New
Eligibility: The §45Z PTC is for the domestic production of clean transportation fuels, including sustainable aviation fuels. Fuels with less than 50 kilograms of carbon dioxide equivalent per million British thermal units (CO2e per mmBTU) qualify as clean fuels eligible for credits
U.S. Code: 26 U.S. Code §45Z
Duration: 3 years
Period of availability: Available for fuels produced after 2024 and used or sold before 2028
Stackability and limitations:
- Producers must be registered as a producer of clean fuel under section 4101
- Fuels must be produced in the U.S.
- To be considered "clean," fuels must emit no more than 50 kilograms of carbon dioxide equivalent per one million British thermal units (CO2e per mmBTU)
- "Transportation fuels" must be deemed "suitable for use as a fuel in a highway vehicle or aircraft"
- Cannot be stacked with §45V or §45Q
Inflation adjustment: Subject to an annual inflation adjustment
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Not applicable
Rates
- Base rate: $0.20/gallon for non-aviation fuel and $0.35/gallon for aviation fuel, multiplied by the emissions factor of the fuel
- Full rate: $1.00/gallon for non-aviation fuel and $1.75/gallon for aviation fuel, multiplied by the emissions factor of the fuel
Guidance:
- Notice 2022-58: Request for Comments on Credits for Clean Hydrogen and Clean Fuel Production (11/3/2022)
- Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan
§45V PTC – Clean hydrogen production tax credit
Funding mechanism: Production tax credit
Technology grouping: Fuels
IRA Section: 13204
New or existing: New
Eligibility: The §45V PTC is for the production of clean hydrogen at a qualified clean hydrogen facility
U.S. Code: 26 U.S. Code §45V
Duration: 10 years from the date the project is placed in service
Period of availability: Credit is for hydrogen produced after 12/31/22. Credit is available for facilities placed in service before 1/1/33
Stackability and limitations:
- Producers must be in the U.S.
- The project developer can make a non-irrevocable election for an ITC (instead of the 45V PTC) as long as the project has not claimed the 45Q PTC for carbon sequestration
- Cannot be stacked with §45Q, §45Z, or §48C
Inflation adjustment: Subject to an annual inflation adjustment
Elective pay (direct pay): Available to tax-exempt entities. Available to non-tax-exempt entities for up to five years
If a non-tax-exempt entity selects elective pay, such entity “shall be treated as having made such election for each of the four succeeding tax years.” During the five-year period, a non-taxexempt entity “may elect to revoke the application” of elective pay for the remainder of the five-year period. The non-tax-exempt entity cannot “subsequently revoke” the elective pay
revocation
Recapture: Not applicable
Rates
- Base rate: $0.60/kg multiplied by the applicable percentage. The applicable percentage ranges from 20% to 100% depending on lifecycle greenhouse gas emissions
- Full rate: $3.00/kg multiplied by the applicable percentage. The applicable percentage ranges from 20% to 100% depending on lifecycle greenhouse gas emissions
Guidance:
- Notice 2022-58: Request for Comments on Credits for Clean Hydrogen and Clean Fuel Production (11/3/2022)
- Notice of proposed rulemaking: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (12/21/2023)
- Final rule pending
§48C ITC – Advanced energy project credit
Funding mechanism: Investment tax credit
Technology grouping: Manufacturing
IRA Section: 13501
New or existing: Existing – modified and extended
Eligibility: For investments in advanced energy projects, as defined in §48C(c)(1). A project that:
- Re-equips, expands, or establishes an industrial or manufacturing facility for the production or recycling of a range of clean energy equipment and vehicles
- Re-equips an industrial or manufacturing facility with equipment designed to reduce greenhouse gas emissions by at least 20 percent
- Re-equips, expands, or establishes an industrial facility for the processing, refining, or recycling of critical materials
U.S. Code: 26 U.S. Code §48C
Period of availability: §48C is an allocated credit. It is available when the application and certification process begins and ends when the credit is fully allocated. Projects must be placed in service within two years of application approval and certification
Stackability and limitations:
- Allocated credit subject to $10 billion cap. At least $4 billion must be allocated to energy communities
- Cannot be stacked with §45X, §48, §48E, §45Q, or §45V
Inflation adjustment: None
Elective pay (direct pay): Only available to tax-exempt entities
Recapture: Subject to recapture per §50
Rates
- Base rate: 6%
- Full rate: 30%
Guidance (since passage of the IRA):
- Notice 2023-18: Initial Guidance for Qualifying Advanced Energy Project Credit Allocation Program Under Section 48C(e) (2/13/2023)
- Notice 2023-44: Additional Guidance for Qualifying Advanced Energy Project Credit Allocation Program Under Section 48C(e) (5/31/2023)
- Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan
§45X PTC – Advanced manufacturing production credit
Funding mechanism: Production tax credit
Technology grouping: Manufacturing
New or existing: New
IRA Section: 13502
Eligibility: The §45X PTC is for domestic manufacturing of components for solar and wind energy, inverters, battery components, and critical minerals
U.S. Code: 26 U.S. Code §45X
Duration: 2023-2032
Period of availability: Credit for critical materials is permanent starting in 2023. For other components, credit phases down over 2030-2032
Stackability and limitations:
- Production of eligible components must be in the U.S.
- Property must be sold to an unrelated party unless making an election under §45X(a)(3)(b)
- Cannot claim §45X credit for property produced at facilities that received the §48C credit
- Credit is subject to a phase-out beginning in 2030 (75%, 50%, 25%, 0%), except for critical minerals
Inflation adjustment: Although §45X is a PTC, the credit is not inflation-adjusted
Elective pay (direct pay): Available to tax-exempt entities. Available to non-tax-exempt entities for up to five years
If a non-tax-exempt entity selects elective pay, such entity “shall be treated as having made such election for each of the four succeeding tax years.” During the five-year period, a non-tax-exempt entity “may elect to revoke the application” of elective pay for the remainder of the five-year period. The non-tax-exempt entity cannot “subsequently revoke” the elective pay revocation
Recapture: Not applicable
Guidance:
- Notice of proposed rulemaking and public hearing (12/15/2023)
- Further guidance pending. The credit is included in the IRS 2023-2024 Priority Guidance Plan
Rates: Rates for the §45X PTC are component-specific and listed on IRS Form 7207. §45X does not have a PWA requirement
Solar energy components
Eligible Component | Value per Unit | Unit |
---|---|---|
Thin film or crystalline photovoltaic cell | $0.04 | Capacity in Wdc |
Photovoltaic wafer | $12.00 | Square meter |
Solar-grade polysilicon | $3.00 | Kilogram |
Polymeric backsheet | $0.40 | Square meter |
Solar module | $0.07 | Capacity in Wdc |
Wind energy components
Eligible Component | Value per Unit | Unit |
---|---|---|
Related offshore wind vessel | 10% | Sales price of vessel |
Blade | $0.02 | Total rated capacity (expressed on a per watt basis) of the completed wind turbine for which such component is designed |
Nacelle | $0.05 | Total rated capacity (expressed on a per watt basis) of the completed wind turbine for which such component is designed |
Tower | $0.03 | Total rated capacity (expressed on a per watt basis) of the completed wind turbine for which such component is designed |
Offshore wind foundation using fixed platform | $0.02 | Total rated capacity (expressed on a per watt basis) of the completed wind turbine for which such component is designed |
Offshore wind foundation using floating platform | $0.04 | Total rated capacity (expressed on a per watt basis) of the completed wind turbine for which such component is designed |
Torque tube and structural fastener components
Eligible Component | Value per Unit | Unit |
---|---|---|
Torque tube | $0.87 | Kilogram |
Structural fastener | $2.28 | Kilogram |
Inverter components
Eligible Component | Value per Unit | Unit |
---|---|---|
Central inverter | $0.0025 | Capacity in Wac |
Utility inverter | $0.015 | Capacity in Wac |
Commercial inverter | $0.02 | Capacity in Wac |
Residential inverter | $0.065 | Capacity in Wac |
Microinverter or distributed wind inverter | $0.11 | Capacity in Wac |
Electrode active materials
Eligible Component | Value per Unit | Unit |
---|---|---|
Electrode active materials | 10% | Costs incurrred by the taxpayer with respect to the production of electrode active materials |
Battery components
Eligible Component | Value per Unit | Unit |
---|---|---|
Battery cell | $35.00 | Capacity in kWh (limitations apply - see instructions to IRS Form 7207 |
Battery module which uses battery cells | $10.00 | Capacity in kWh (limitations apply - see instructions to IRS Form 7207 |
Battery module which does not uses battery cells | $45.00 | Capacity in kWh (limitations apply - see instructions to IRS Form 7207 |
Critical minerals
Eligible Component | Value per Unit | Unit |
---|---|---|
Applicable critical minerals | 10% | Costs incurrred by the taxpayer with respect to the production of such minerals |
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On April 25, the Treasury and IRS published final regulations for the Inflation Reduction Act’s tax credit transfer mechanism. The IRS also published a press release and updated their transferability FAQs.
The final regulations carried few surprises – other than, perhaps, arriving earlier than some market participants predicted – and preserved the status quo set by the June 2023 guidance.
At Reunion, we welcomed this "non-event" and the clarity it provided, and wanted to highlight several key consistencies.
Highlights from the final regulations
Individuals, trusts, estates, and closely held C corporations remain largely on the sidelines
Despite “many comments” calling for a change, widely held C corporations will remain the primary buyers of transferable tax credits. While this decision will likely decrease overall liquidity in the tax credit market, it will also limit the potential for fraud and abuse.
Passive activity rules generally limit individuals, trusts, estates, and closely held C corporations to applying transferable tax credits to passive income – not active income. The final regulations did not adjust this stance. (However, a potential exception exists for certain closely held C corporations, which allows them to offset active income with tax credits.)
Deprecation cannot be transferred
The IRS did not change its stance on depreciation. As the FAQ states, “Only a taxpayer that has an ownership interest in the project may claim tax depreciation. Transferability does not allow depreciation benefits to be transferred.”
Bonus credits cannot be sold separately
The IRA created three bonus, or adder, credits, which can increase the value of a clean energy project’s tax credits:
- Energy communities
- Low-income communities
- Domestic content
The Treasury’s June guidance stated that bonus credits cannot be sold separately from a project’s other credits. A developer cannot, in other words, sell its base credits to one company and its bonus credits – perhaps at a different price per credit – to another company.
Instead, all credits must be sold as “vertical slices” and be pari passu to one another. In practice, if a single project has multiple buyers for its credits, all buyers have the same risk exposure.
April’s regulations did not change the Treasury’s position.
The "intends to purchase" provision remains unchanged
Tax credit buyers can still "take into account a specified credit portion that it has purchased, or intends to purchase, to calculate its estimated tax payments." Of course, buyers remain liable for any underpayments.
The regulations clarified that the "intends to purchase" language "illustrates that all the requirements of proposed §1.6418-2(b) do not have to be met for a transferee taxpayer to take the expected eligible credit into account in its estimated tax calculations."
Generators of §45X, §45V, and §45Q credits can make facility-specific elections for transferability or direct pay
An advanced manufacturer’s decision to use transferability or direct pay to monetize their §45X tax credits need not be binary. If a manufacturer has multiple facilities, they can make the transferability-or-direct-pay decision at the facility level. If a manufacturer only has one facility, however, their decision is binary.
The same optionality holds true for the §45V PTC for clean hydrogen and §45Q PTC carbon capture, although the timing of the election varies by credit:
- §45V PTC: The direct pay/transfer election is made during the taxable year the qualified clean hydrogen production facility is placed in service
- §45Q PTC: The direct pay/transfer election is made during the taxable year the “single process train” is placed in service
- §45X AMPC: The direct pay/transfer election is made during the taxable year in which eligible components are produced
Importantly, because the §45X election is made during the taxable year in which an eligible component is produced, production facilities that predated the IRS may be eligible for the credit.
Advanced cash payments for multi-year PTCs are not permitted – but borrowing against expected future tax credit payments is permitted
Although “upfront payments for PTCs determined in future taxable years are standard in tax equity transactions,” the final regulations stated that transferred PTCs must be paid for in cash one year at a time. This holds true for ten- and 12-year PTCs.
Permitting advanced payments would “raise several complex legal and administrative issues, such as whether an excessive credit transfer has occurred or if the eligible taxpayer has gross income if prepaid eligible credits were not transferred in a later tax year."
On an encouraging note, the final regulations specifically state that “there is no prohibition on either a transferee taxpayer” – that is, a tax credit buyer – “or another third-party loaning funds to an eligible taxpayer, including loans secured by an eligible credit purchase and sale agreement.”
Intermediaries can serve as brokers but not dealers
The final regulations, unsurprisingly, left unaltered the assumed role of tax credit intermediaries (like Reunion) in the transferability market. Intermediaries can serve as brokers and facilitators in tax credit transfers, helping to match and advise buyers and sellers.
Intermediaries cannot, however, serve as dealers, effectively taking ownership of a tax credit with the intent of transferring/selling it again.
“Required minimum documentation” remains the same
The final regulations acknowledge calls for an increase to the amount of required minimum documentation that an eligible taxpayer must provide to a transferee taxpayer to make a valid transfer.
Nonetheless, the Treasury and IRS left the required minimum unchanged. Perhaps as a nod to the validity of increasing the required minimum, the final regulations remind market participants that, “...while the required minimum documentation requirements are the same for all taxpayers, any particular agreement between an eligible taxpayer and transferee taxpayer may go beyond the required minimum documentation based on the arrangement of the parties. The proposed regulations allowed sufficient flexibility for market participants to determine if more information is necessary in a particular transaction, while balancing the burden of producing the required minimum documentation required to make a transfer election.”
The final regulations also remind market participants that "§6418(g)(2)(B) specifically places a due diligence responsibility on the transferee taxpayer."
Improvements likely coming to the pre-registration portal
The IRS opened the tax credit pre-registration portal in December to significant fanfare. But, as with any brand-new IT system, there have been calls for improvement.
While the IRS would not commit to set application review times, it left the door open to "continue to review the efficiency of the registration portal, including functionality responses from the public, to determine whether changes should be implemented or whether additional guidance or publications should be issued."
Plenty more guidance to come in the next 20-ish business days
In Norton Rose Fulbright’s annual Cost of Capital call, the panelists aptly brought attention to the Congressional Review Act, which “is a tool Congress can use to overturn certain federal agency actions.”
With respect to the Inflation Reduction Act, an incoming Congress (backed by a Trump administration) could use the CRA to unwind IRA regulations that were issued within 60 legislative days of the previous Congress.
Although the exact date for the beginning of the 60-day window remains to be seen, it’s potentially in late May or early June. This gives the Treasury and IRS a little over 20 business days to issue a backlog of IRA-related guidance and regulations.
The IRS 2023-2024 Priority Guidance Plan details what guidance the IRS is prioritizing through the end of the plan year, which is June 30, 2024.
Discuss the regulations with Reunion
Please contact Reunion's transactions team to understand how these final regulations could impact your organization's plans to purchase clean energy tax credits.
Read more
The market for clean energy tax credit transfers has accelerated rapidly in 2024, as corporate tax and treasury leaders see a significant new opportunity to reduce tax liabilities and increase corporate cash availability.
A complete transferable clean energy tax credit transaction, from identifying the opportunity to closing the deal, can be summarized in seven key steps.
Duration
Varies by company.
Goals and activities
Goals | Key activities |
---|---|
Develop key tax credit purchase criteria and success measures | Confirm your company's interest in a tax credit transfer that meets specific criteria – for instance, credit pricing, type (48 ITC, 45 PTC, 45X APMC), technology (solar, wind, battery storage, critical minerals), payment terms, indemnification and insurance |
Align internal stakeholders | Get an understanding of the needs of your tax, treasury, accounting, legal, and ESG teams. At the same time, understand who is ultimately resposible for the investment decision |
How Reunion helps
Through an introductory call, Reunion's transactions team can equip your company with insights on eligibility, appropriateness, market dynamics, and risk. We can also help your team prepare a business case/investment committee memo and provide supporting materials. For larger organizations, Reunion has organized tax credit "workshops," which we have found are particularly effective for aligning multiple functional teams.
Key resources
- Transferable tax credit handbook
- How early investors are approaching clean energy tax credits
- Sample business case or investment committee memo (by request)
Duration
One to three weeks.
Goals and activities
Goals | Key activities |
---|---|
Identify project(s) | Sign NDA to gain more information about tax credit opportunities available on the Reunion platform |
Negotiate and sign term sheet(s) | Formally express interest in a project through issuance and negotiation of term sheet, which defines key transaction terms and kicks off an exclusivity period |
How Reunion helps
Reunion takes a "push" and "pull" approach when helping companies find projects that most align with their needs. On the "push" front, we curate a list of tax credit opportunities based on the criteria we identified in step one and share it with your team. For many companies, we do this on a rolling basis as new projects join our platform. On the "pull" front, we provide your team with access to our managed tax credit marketplace, where we have over $7B (and growing) in near-term tax credits available.
Once your team has the right project(s) in mind, Reunion will populate our form term sheet on your company's behalf. We'll levarage our market intelligence to ensure your proposal is competitive and assist you in negotiating key terms, like timing of payment, indemnification, and tax credit insurance.
Key resources
- Tax credit marketplace
- Transferable tax credit transactions tracker
- Unlocking the economic benefits of tax credits before payment
- Sample term sheet (by request)
Duration
One to two weeks.
Goals and activities
Goals | Key activities |
---|---|
Identify potential issues, if any, upfront before spending significant time and expense | Review Reunion’s preliminary due diligence note to better understand potential risks and risk mitigation |
Make a decision to proceed with the transaction | Assess the risk / reward profile of the transaction |
How Reunion helps
Reunion conducts a preliminary screen to identify any major issues up front ("fatal flaw" due diligence analysis). From that point, we consult with your team to assess risks and recommend appropriate mitigation strategies. Importantly, this step ensures alignment of incentives: we do not want to move a transaction forward unless there is a high probability of success.
We also provide validated market intelligence to compare your proposed transaction to the risk/reward profile of similar tax credit opportunities in the market.
Key resources
- Buying and selling clean energy tax credits
- What should corporations expect to pay for clean energy tax credits?
- Due diligence checklist (by request)
Duration
Two to six weeks. The precise duration depends largely on the number and relatively complexity of projects in the transaction.
Goals and activities
Goals | Key activities |
---|---|
Conduct comprehensive financial, legal and technical due diligence to gain comfort in moving forward with the transaction | Ensure that proper due diligence has been performed on the project, covering the following topics: qualification, structure, recapture, prevailing wage and apprenticeship compliance, bonus credit adder qualification, and risk mitigants (indemnification and tax credit insurance) |
How Reunion helps
Reunion spearheads the due diligence process by:
- Reviewing documents provided by the Seller, and requesting any missing or incomplete information
- Creating and organizing a data room, ensuring that due diligence documentation meets Reunion's checklist of required documentation
- Reunion will produce a summary due diligence memorandum summarizing our findings and highlighting any areas of concern
- If you are working with additional diligence advisors, Reunion will work closely with advisors to organize and accelerate their review process, reducing costs
Key resources
- Due diligence checklist (by request)
Duration
This step is optional and runs in parallel to step 4.
Goals and activities
Goals | Key activities |
---|---|
Procure tax credit insurance to mitigate risk of tax credit disallowance or recapture | Work with Reunion to ensure that tax credit insurance adequately covers desired risks. Ensure that insurance coverage levels are adequate in scope and amount |
How Reunion helps
Reunion can help companies decide if insurance is an appropriate risk mitigation tool for their transaction. If we collectively determine that tax credit insurance makes sense, we can advise on insurance offerings, including the scope of coverage – e.g., structure, qualification, recapture, PWA, bonus credit adders – and where gaps might exist.
We can also help you validate that the insurance policy is appropriately sized and includes penalties and tax gross-up and contest costs.
Key resources
Duration
This step runs in parallel to step 4.
Goals and activities
Goals | Key activities |
---|---|
Negotiate and sign a tax credit transfer agreement | Review the legal contract to ensure that Buyer and Buyer counsel are satisfied with the terms |
How Reunion helps
Reunion streamlines the negotiation process for buyers and sellers by providing a template legal document and helping parties focus on the most pertinent deal topics.
Key resources
Duration
Ongoing duration depending on credit type.
Goals and activities
Goals | Key activities |
---|---|
Navigate various IRS filing deadlines in the months following the transaction | File IRS paperwork and stay compliant with the follow up requirements. Stay up to date on the latest market trends |
How Reunion helps
Our transactions team will issue both parties reminders about filing requirements and deadlines, including tax forms and compliance. In subsequent tax years/quarters, Reunion will provide early acccess to new deals.
Key resources
Reunion’s team of clean energy and tax credit experts are here to support you through the entire process of buying and conducting due diligence on IRA tax credits. We draw on our deep expertise to help you navigate tax credit transactions, and our marketplace features the widest pool of tax credit opportunities available in the industry.
Our key differentiators include:
- Widest pool of high quality tax credits: We curate opportunities from our $7B marketplace, featuring 6+ supported technologies and projects ranging from under $3M to $300m+
- Extensive educational materials: We offer an extensive resource library featuring content on financial, legal, and market-related topics pertaining to IRA tax credits
- Hands-on due diligence: We support buyers throughout the transaction process, ensuring that the due diligence is performed at high quality and that risks are minimized upfront, saving you time and expense
- Industry-leading transaction team: Our transaction team consists of industry veterans, with experience raising $5+ billion in clean energy project financing `with partners such as US Bank, JP Morgan, Wells Fargo, Bank of America, Key Bank, PNC, Nord/LB, D.E. Shaw, First Reserve, and over a dozen Fortune 500 companies
- Market intelligence tools: Available upon request, we offer proprietary insights on tax credit pricing and data on key trends
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Reunion is excited to host quarterly “office hours” for clean energy developers who would like to learn more about our marketplace and get a pulse on the overall transferability market.
Hosted on a quarterly basis
We will generally hold office hours on a quarterly basis and open registration one or two months in advance.
Quarter | Date | Time | Registration | Recording |
---|---|---|---|---|
Q2 2024 | Thursday, May 2 | 2:00pm - 3:00pm ET | Zoom | YouTube |
Q3 2024 | Thursday, August 1 | 2:00pm - 3:00pm ET | Zoom | |
Q4 2024 | TBD | 2:00pm - 3:00pm ET | ||
Q1 2025 | TBD | 2:00pm - 3:00pm ET |
Designed for clean energy developers and manufacturers
Our office hours are designed for clean energy developers and manufacturers who have transferred, or are planning to transfer, IRA tax credits over the next 12 months. Developers need not have projects in Reunion's marketplace to participate.
Co-hosted by Reunion's founders
Reunion's founders, Billy Lee and Andy Moon, will co-host the hour-long sessions.
Billy and Andy pioneered solar financing structures with tax equity and private equity investors, leading some of the first solar transactions with institutions such as US Bank, JP Morgan, Wells Fargo, Bank of America, Key Bank, PNC, Nord/LB, D.E. Shaw, and First Reserve.
Questions welcome!
We want our office hours to be interactive, so please bring any questions you have, whether related to current market conditions, pricing, or commercial terms.
You're welcome to ask questions beforehand.
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The latest energy community guidance, which meaningfully expanded the number of qualifying areas, placed the 10% adder back in the spotlight for the transferable tax credit marketplace. At the same time, Reunion has observed a marked increase in the number of projects in our marketplace claiming the energy community bonus.
While our transferable tax credit handbook goes deep on energy communities, we wanted to share a comprehensive (and refreshed) look at the adder.
Our guide begins with the basics, so we invite you to jump ahead.
- Background and scope
- Credit and project eligibility
- Diligence
- Guidance
- Annual updates to areas qualifying as energy communities
- Resources
The Inflation Reduction Act created three bonus credits, or "adders"
The Inflation Reduction Act (IRA) created three "bonus" credits that can increase the value of a clean energy project's transferable tax credits:
- Domestic content: 10% bonus
- Energy community: 10% bonus
- Low-income community: 10% or 20% bonus
The energy community adder provides a 10% bonus credit
The energy community bonus provides a 10% increase to a project's credit value if the underlying project is located in an energy community (and meets prevailing wage and apprenticeship requirements).
A utility-scale solar project, for instance, that meets PWA requirements would receive tax credits worth 30% of its eligible cost basis. If the same project is located in an energy community, it would receive tax credits worth 40% of its eligible basis.
The IRA defines three types of energy communities
To qualify for the energy community bonus, a project must be located in at least one of three energy community "categories."
Category 1: Brownfield
A brownfield site is defined in 42 U.S.C. § 9601(39)(A) as "real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant" (as defined under 42 U.S.C. § 9601), and includes certain "mine-scarred land" (as defined in 42 U.S.C. § 9601(39)(D)(ii)(III)). A Brownfield site does not include the categories of property described in 42 U.S.C. § 9601(39)(B).
Three types of sites qualify as a brownfield under a safe harbor:
- Existing brownfield: Brownfields that are already tracked by a federal, state, territorial, or federally-recognized Indian tribal brownfields program. Many states, like Idaho and New York, have their own brownfields programs with supporting maps. A valid brownfield site could be tracked by a state program but not a federal program, and vice versa
- Phase II assessment: A Phase II Assessment has been completed with respect to the site and such Phase II Assessment confirms the presence on the site of a hazardous substance as defined under 42 U.S.C. § 9601(14), or a pollutant or contaminant as defined under 42 U.S.C. § 9601(33)
- Phase 1 assessment (for projects with a nameplate capacity of not greater than 5MWac): A Phase I Assessment has been completed with respect to the site and such Phase I Assessment identifies the presence or potential presence on the site of a hazardous substance, or a pollutant or contaminant.
Category 2: Coal closure
A census tract (or directly adjoining census tract):
- in which a coal mine has closed after 1999; or
- in which a coal-fired electric generating unit has been retired after 2009
Category 3: Statistical area
A "metropolitan statistical area" (MSA) or "non-metropolitan statistical area" (non-MSA) that has (or had at any time after 2009):
- 0.17% or greater direct employment or 25% or greater local tax revenues related to the extraction, processing, transport, or storage of coal, oil, or natural gas; and
- has an unemployment rate or above the national average unemployment rate for the previous year
The scope of "direct employment" is determined by ten NAICS codes.
No double bonus for multiple energy communities
If a clean energy project is located in two energy communities – a brownfield site within a coal community, for instance – the bonus remains 10%. Developers cannot double up.
Bonus credits cannot be sold in stand-alone tranches
Bonus credits are not treated differently from base credits for the purpose of transferability. Treasury guidance released in June 2023 specified that all transferable credits must be sold as “vertical slices” and be pari passu to one another, as opposed to “horizontally” bifurcating bonus credits from base credits.
Four IRA credits are eligible for the energy community bonus
The IRA created 11 transferable tax credits, four of which are eligible for the energy community bonus:
- §45 PTC: Electricity produced from certain renewable resources
- §45Y PTC: Clean electricity production credit
- §48 ITC: Energy credit
- §48E ITC: Clean electricity investment credit
§48 and §48E ITC eligibility determined on placed-in-service date
For projects that claim an investment tax credit under §48 or §48E, eligibility for the energy community bonus credit is determined on the date that the project is placed in service (PIS) and is not tested again.
Because eligibility is determined on a PIS date that is subject to potential delays, developers should think carefully about how to incorporate the statistical area category into their financial assumptions.
The statistical area category is determined annually, based on the prior year's unemployment rate. As the IRS FAQs state, "Because an MSA's or non-MSA's status as an energy community depends on its unemployment rate for the previous year, an MSA or non-MSA that qualifies as an energy community in one period might not qualify as an energy community in a later period if its unemployment rate for the previous year falls below the national average."
§45 and §45Y PTC eligibility determined annually with a beginning-of-construction safe harbor
For projects that claim a production tax credit under §45 or §45Y, eligibility for the energy community bonus credit must be determined every year during the ten-year PTC period. Theoretically, a wind project could qualify one year under the statistical area category but not qualify the following year because of a change in employment rates.
However, the IRS created a safe harbor for PTC projects with beginning-of-construction dates on or after January 1, 2023. If the project owner determines that the project is eligible for the energy community bonus credit on the date construction is considered to have started for tax purposes, then the project will qualify for the bonus credit for the entire ten-year PTC period and is not tested again.
"Legacy" §45 PTCs are not eligible for energy community bonus
Projects that generate §45 PTCs that were placed in service before December 31, 2022 are not eligible for the energy community bonus, even if the project happens to be located in an energy community and is within its ten-year period of credit generation.
The December 31, 2022 date is set in the IRA itself (H.R.5376).
50% of a project's nameplate capacity (or square footage) must be in an energy community
A project qualifies for the energy community bonus if at least half (50%) of its nameplate capacity is in an energy community. According to the IRS, nameplate capacity is the DC capacity that a project is capable of producing on a steady-state basis during continuous operation under standard conditions.
For battery storage projects, at least half (50%) of the storage capacity, as measured in megawatt hours, should be in an energy community.
Lastly, for projects that do not generate nor store energy, like biogas, the 50% threshold is measured on a square footage basis.
When performing due diligence on the energy community bonus, it's helpful to approach the process based on the credit type and energy community category.
Credit type
ITCs
Tax credit buyers should request documentation that demonstrates when and where the project was placed in service. Then, buyers and their advisors should crosswalk that location to an appropriate energy community siting resource, like one of the IRS's appendices. (We provide links to these appendices in the guidance section of this post.)
When validating a project's location, it's important to keep the "50%" rule in mind.
PTCs
Due diligencing the energy community bonus for PTCs is effectively the same as ITCs, although buyers will want to validate when and where the project began construction (versus when and where the project was placed in service). Once again, it's important to keep the "50%" rule in mind.
Energy community category
As far as each category is concerned, the statistical area and coal closure categories are relatively straightforward from a due diligence standpoint: the IRS has published lists of areas that qualify for each. The brownfield category, however, may present a slightly more nuanced due diligence process.
Statistical area
It's important to recall that the statistical area category changes every year, based on the prior year's unemployment rate. As we'll discuss below, the IRS is obligated to publish updates to this category every year, generally in May.
Coal closure
Unlike the statistical area category, the coal closure category cannot shrink – that is, once an area qualifies as a coal closure, it remains as such for the duration of the energy community bonus.
However, the coal closure category can expand, and we fully expect it to do so. According to a 2022 analysis by the Energy Information Agency (EIA), nearly a quarter of the operating U.S. coal-fired fleet is scheduled to retire by 2029. Every closure will add more census tracts to the list of areas eligible for the energy community bonus.
Brownfield
The IRS has not published – and, as far as we know, has no plans to publish – a consolidated list of areas that qualify as brownfields for purposes of the energy community bonus. In fact, the DOE energy community map doesn't even include federally-recognized brownfield sites. (The EPA, however, maintains a list of federally-recognized brownfields in its cleanups in my community map.)
We doubt the IRS or any federal agency will publish a definitive list of brownfields. There are simply too many moving parts across federal, state, local, and tribal brownfields programs.
So, an opinion from an environmental attorney may be warranted, and the scope of the opinion will vary based on which of the three brownfields safe harbors a project is claiming.
Latest guidance expands the number of areas that are eligible for the energy community bonus
The most recent IRS guidance, Notice 2024-30, broadened eligibility for the energy community bonus through two key changes:
- Expansion of the "nameplate capacity attribution rule"
- Inclusion of two additional NAICS codes – which are in our list above – for determining the fossil fuel employment rate for a statistical area category
Expansion of the nameplate capacity attribution rule
The "nameplate capacity attribution rule" pertains to projects with offshore generation – namely, offshore wind – that have a nameplate capacity but are not located within a census tract, an MSA, or a non-MSA. The rule, essentially, allows developers to allocate their offshore nameplate capacity onshore for purposes of qualifying for the energy community bonus.
Prior to Notice 2024-30, the attribution rule generally allowed offshore wind projects to qualify for the energy community bonus if their power-conditioning equipment closest to the point of interconnection was in an energy community.
Notice 2024-30 expanded the nameplate capacity attribution rule to include not only power-conditioning equipment, but also supervisory control and data acquisition (SCADA) equipment.
SCADA equipment must be owned by the developer and located in an "energy community project port." To qualify as an energy community project port, a port must:
- Be used "either full or part-time to facilitate maritime operations necessary for the installation or operation and maintenance" of the project
- Have a "significant long-term relationship" with the project, meaning the developer owns or leases all or part of the port for a minimum term of ten years
- Be the location at which staff employed by, or working as independent contractors for, the project are based and perform functions essential to the project's operations. Essential functions include "management of marine operations, inventory and handling of spare parts and consumables, and berthing and dispatch of operation and maintenance vessels and associated crews and technicians"
Inclusion of two additional NAICS codes
Notice 2024-30 added two additional NAICS codes for determining the fossil fuel employment rate for a statistical area category:
- 2212: Natural gas distribution
- 23712: Oil and gas and pipeline and related structures construction
These NAICS codes cover workers in local gas distribution companies and construction workers on oil and gas pipelines.
According to Norton Rose Fulbright, "The biggest additions to the list of potentially eligible counties are in six Midwestern states: Minnesota (57), Missouri (57), Illinois (28), North Dakota (23), Wisconsin (23) and Indiana (20)."
The IRS has released five pieces of energy community guidance, with regulations to come soon
Energy community regulations should arrive by June 30, 2024
As Notice 2024-30 notes, proposed regulations are forthcoming. Until then, "taxpayers may rely on the rules described in sections 3 through 6 of Notice 2023-29, as previously clarified by Notice 2023-45 and modified by section 3 [of] this notice, for taxable years ending after April 4, 2023."
Based on the Q2 update to the IRS 2023-2024 Priority Guidance Plan, energy community regulations should arrive before the end of the current "plan year," which concludes on June 30, 2024.
Where to find the latest guidance
The IRS and Treasury maintain lists of IRA-related guidance, including guidance specific to the energy community adder. Although the lists generally overlap, there may be differences based on when each website was last updated.
Below is a close look at all the guidance that's been released through March 2024.
Notice 2022-51: Request for Comments on Prevailing Wage, Apprenticeship, Domestic Content, and Energy Communities Requirements under the Inflation Reduction Act of 2022
- Date: October 5, 2022
- News release: IRS
- Companion documents: N/A
Notice 2023-29: Energy Community Bonus Credit Amounts under the Inflation Reduction Act of 2022
- Date: April 4, 2023
- News release: IRS
- Companion documents: Appendix A, Appendix B, Appendix C
Notice 2023-45: Energy Community Bonus Credit Amounts under the Inflation Reduction Act of 2022
Notice 2023-47: Energy Community Bonus Credit Amounts or Rates (Annual Statistical Area Category Update and Coal Closure Category Update)
- Date: June 15, 2023
- News release: IRS
- Companion documents: Appendix 1, Appendix 2, Appendix 3
Notice 2024-30: Energy Community Bonus Credit Amounts under the Inflation Reduction Act of 2022
- Date: March 22, 2024
- News release: IRS
- Companion documents: Appendix 1, Appendix 2
Expect energy community eligibility updates every May, beginning in 2024
According to Notice 2023-29, "The Treasury Department and the IRS intend to update the listing of the Statistical Area Category based on Fossil Fuel Employment annually. These updates generally will be issued annually in May."
The first update should arrive in May 2024 – that is, next month.
DOE, EPA, and IRS have provided energy community eligibility and project siting resources
U.S. federal agencies who are responsible for administering or managing parts of the energy community bonus credit have published several key resources that are valuable to buyers, sellers, and their advisors:
- Department of Energy (DOE): Energy community map
- IRS: Frequently asked questions
- DOE National Energy Technology Laboratory (NETL): Frequently asked questions
- Environmental Protection Agency (EPA): RE-powering America's land initiative
- EPA: Cleanups in my community
- Interagency working group: Energy community tax credit bonus
To learn more, you can download our 100-page transferable tax credit handbook or start a conversation with our transactions team.
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