Guide
Transferable Tax Credit Handbook Version 3.1
Read by over 4,000 members of the transferable tax credit market
This version does not reflect any changes imposed by the 2025 budget reconciliation. We will be updating this handbook soon.
Reunion’s transferable tax credit handbook is a 140-page comprehensive guide to buying and selling tax credits. Since its initial launch, the handbook has been downloaded by over 4,000 members of the transferable tax credit market, including tax credit buyers, sellers, and professional advisors.
The handbook covers the transferability process from start to finish, including key topics such as:
- Technical considerations for buying and selling credits: tax treatment for buyers and sellers, guidance on transfer election statements, required minimum documentation, and excessive credit transfers and associated penalties
- Due diligence considerations for the major tax credits: §45 production tax credits, §45X advanced manufacturing production credits, and §48 investment tax credits
- Pricing trends: major drivers of tax credit pricing including risk, complexity, size of transaction, and terms such as payment timing, insurance, and strength of indemnity
- Cash flow considerations: detailed examples of the cash flow impact of tax credit payments, with a focus on structures where buyers can achieve the full benefit of tax credits prior to paying cash
- Risk mitigation: how buyers can protect their tax credit purchase through seller indemnity, parent guaranty, and tax credit insurance
- Tax credit transfer agreements: common points of negotiation between buyers and sellers during term sheet and definitive legal documentation
- Tax credit matrix: summary of the 11 types of tax credits that can be transferred and their characteristics, including bonus credit adders and compliance with prevailing wage and apprenticeship requirements
Additional Resources
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