The Future of IRA Credit Transfers: Predictions From the First Year - Tax Notes
While plenty of uncertainty for the future remains, it’s clear that credit transfers authorized under the IRA have solidly taken off. That may make them more difficult to end or revise, as illustrated by a March 9 letter from 21 House Republicans to their colleagues arguing against repeal.
Andy Moon, CEO of Reunion, provided comments to Tax Notes on the rapid materialization and evolution of the IRA credit transfer market. He noted that 2024 began with few buyers, but by midyear, comfort with the process grew, leading to a surge in transactions where credits would sell within days or weeks by year-end. Moon observed that while purchasers are committing to production tax credits for multiple years, there's reluctance for long-term commitments to ITCs expected in 2026 and beyond, with only a few large buyers engaging in extensive negotiations for such deals. He mentioned that buyers who acted early in 2024 generally secured lower prices, and while the learning curve of 2024 won't repeat, early movers in 2025 might still benefit by committing despite legislative uncertainty (see Andy’s breakdown of The One, Big, Beautiful Bill). Moon also highlighted that purchase agreements are now heavily negotiating change-in-law provisions, and the time to close deals has significantly reduced, indicating a maturing market.
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