Hear from Your Peers: Transferable Tax Credits with Hormel & Gallup

Reunion hosted a buyer-focused webinar with Jim Fleming of Hormel and Adam Fritz of Gallup. Jim and Adam shared important lessons they've learned in the transfer process, including getting internal buy-in, origination and sourcing investments, deal structure negotiations, and due diligence.

View a segment of the conversation below:

Insights from your peers:

  • Secure Internal Buy-In Up Front: Align with relevant stakeholders (which often include the CFO, legal, and treasury teams) early on to establish your company's goals and risk tolerance. This internal alignment is crucial for moving quickly and decisively on potential deals.
  • Negotiate Beyond Price: While price is top of mind for most buyers, other terms such as a strong seller indemnity and favorable payment timing can be equally important. Buyers also often negotiate for sellers to cover a capped amount of legal and diligence fees.
  • Key Buyer Metrics Include Cash Savings, Timing of Payment and Strength of Seller: Buyers noted that the amount of cash savings and resulting impact on ETR was their primary consideration. Timing of payment is also significant to ensure there isn't too large of a "prepayment" on taxes. Finally, partnering with a strong seller is critical in the event there is an IRS challenge down the road.
  • Conduct Thorough Due Diligence: Even with a strong seller guarantee, buyers must conduct comprehensive due diligence. Experienced legal counsel, and the right broker / advisor can help streamline the due diligence process and ensure proper risk mitigation.
  • Monitor Legislative Changes: Tax credit transfer activity has picked up since the proposed reconciliation bill passed in the House, which gave the market confidence that there will not be a retroactive repeal of credits. However, the proposed bill will also lower tax liability for many buyers, which will impact the volume of credits a buyer can purchase.

Additional Resources

Guides and handbooks from Reunion.

May 21, 2025

Section 45X AMPC Due Diligence Guide

A roadmap for assembling a due diligence package that satisfies the documentation needs of enterprise tax credit buyers, and provides tax credits sellers with insights on the type of documentation they will need to prepare.

Guide

May 8, 2025

Section 45 PTC Due Diligence Guide

A roadmap for assembling a due diligence package that satisfies the documentation needs of enterprise tax credit buyers, and provides tax credits sellers with insights on the type of documentation they will need to prepare.

Guide

May 8, 2025

Section 48 ITC Due Diligence Guide

A roadmap for assembling a due diligence package that satisfies the documentation needs of enterprise tax credit buyers, and provides tax credits sellers with insights on the type of documentation they will need to prepare.

Guide

March 17, 2025

Transferable Tax Credit Handbook Version 3.1

A comprehensive guide to buying and selling tax credits. Navigate the transferability process from start to finish, from identifying appropriate credits to due diligence and legal documentation

Guide

March 10, 2025

Transferable Tax Credits in 2025: The Buyer Perspective

The transferable tax credit market remains active and resilient even in a fluctuating policy landscape. Learn what buyers are saying about their 2025 plans, and see the latest pricing data and insights.

Guide

October 10, 2024

Q3 2024 Market Intel: Transferable Tax Credit Pricing and Market Trends

Leveraging verified data from ~$10B of cumulative transaction volume, our quarterly market intel report explores pricing, market participation, and emerging commercial trends across §48 ITCs, §45 PTCs, and §45X AMPCs.

Guide

April 8, 2024

Transferable Tax Credit Payment Structures

Examine four payment structures under which corporate taxpayers can realize most or all of the benefit of a tax credit before paying the seller.

Guide

February 5, 2024

Timing of Transferable Tax Credit Purchases

Transferable tax credits are a useful tool for profitable companies looking to manage their tax position. When buying transferable tax credits, however, companies must consider their tax year-end in conjunction with that of the seller in order to claim the credits correctly and to the greatest extent possible.

Guide

September 27, 2023

Economic Model for Tax Credit Buyers

Download our transferability economic model for corporate taxpayers and align it with your company's fact pattern to ensure that you are aware of the post-tax nature of tax credit return metrics.

Guide

Reunion Accelerates Investment Into Clean Energy

Reunion’s team has been at the forefront of clean energy financing for the last twenty years. We help CFOs and corporate tax teams purchase clean energy tax credits through a detailed and comprehensive transaction process.

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