Transferable Tax Credit Payment Structures

Treasury guidance made clear that corporate taxpayers can offset their quarterly estimated tax payments using tax credits they “intend to purchase,” opening the door for buyers to realize most or all of the benefit of a tax credit before paying the seller.

Corporate tax directors and treasurers are increasingly focused on these opportunities, which do not require their companies to go “out of pocket” to invest in tax credits.

This resource outlines four scenarios where buyers can realize tax benefits prior to cash outlay:

  • Scenario 1: Commit to PTCs or AMPCs in Q1. Pay quarterly in arrears
  • Scenario 2: Commit to portfolio of ITCs in Q1. Pay quarterly in arrears
  • Scenario 3: Commit to ITCs, PTCs, or AMPCs in Q1. Pay in Q3 or Q4
  • Scenario 4: Purchase "top-up" ITCs, PTCs, or AMPCs in Q4

The Excel file includes several variables that corporate taxpayers can tailor to their company.

To learn more about the model, please read our companion insights article, unlocking the economic benefits of tax credits before cash payment.

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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