Section 48 ITC Due Diligence Guide

Transferable tax credits are sold at a discount to face value, providing attractive financial benefits to corporate investors. They are not without risk, however, and tax credit buyers should have a clear sense of how to identify, track, and mitigate relevant risks.

This due diligence checklist and documentation guide gives tax credit buyers, sellers, and their respective advisors a set of shared expectations on the required analysis and documentation for §48 investment tax credits.

The guide covers:

  • Major deal participants
  • Seller/sponsor diligence
  • Structure diligence
  • Qualification
  • Recapture
  • Prevailing wage and apprenticeship compliance/exemption
  • Bonus credits
  • Tax credit insurance

Additional Resources

Guides and handbooks from Reunion.

March 13, 2026

Reunion Market Monitor

Reunion’s Market Monitor provides a comprehensive view of transferable tax credit pricing, terms, and market dynamics.

Guide

March 3, 2026

Companies That Have Purchased Transferable Tax Credits

Companies of all sizes, across industries and regions, have disclosed purchases of transferable tax credits.

Guide

October 9, 2025

Compliance Guidebook: PWA, FEOC and BoC

Reunion's Compliance Guidebook is a comprehensive resource to help participants in the clean energy tax credit marketplace confidently manage requirements for Prevailing Wage and Apprenticeship, Foreign Entity of Concern, and Beginning of Construction.

Guide

August 7, 2025

Transferable Tax Credit Handbook Version 4.1

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

May 21, 2025

Section 45X AMPC Due Diligence Guide

A focused due diligence documentation checklist for manufacturers and buyers navigating §45X advanced manufacturing credits, with clear guidance on tax credit rates, qualification criteria, eligible components and critical minerals, and more.

Guide

May 8, 2025

Section 45 Production Tax Credit Due Diligence Guide

A practical checklist for the due diligence of production tax credits, with details for enterprise tax credit buyers and sellers on tax credit rates, structure, PWA compliance/exemption, and more.

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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