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.

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November 4, 2024

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.

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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.

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August 1, 2024

Transferable Tax Credit Handbook Version 3.0

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

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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.

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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.

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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.

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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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