Tax Credits & Transferability 2024: Optimizing Post-IRA Opportunities

Two years ago, the IRA created a revolutionary new regime to provide tax credits for an expanded range of clean energy investments, using tax credit sales to expand the pool of potential investors to include corporations that hitherto had little if any experience in the energy sector, but also introducing a series of adders that could substantially decrease capital costs. While this clearly represented, and represents, a golden opportunity to mobilize funding for a huge number of clean energy projects, it set market participants the task of discovering exactly how to structure financings that could monetize depreciation, capitalize on step-ups in FMV (fair market value), and protect participants when claiming new incentives—all necessary to utilize the full range of capital now available from both traditional tax equity and corporate tax credit buyers.

Today, however, the market is field-testing a series of structures and tools to optimize the financing of a wide variety of projects using the full range of tax credits. What lessons are being learned in newly closed T-flip and transfer deals? How are players dealing with the risks of claiming domestic content, prevailing wage and apprenticeship (PWA), and energy community incentives? If you want to take full advantage of the remarkable techniques now available to finance traditional solar and wind projects, as well as storage, CCS, RNG, manufacturing, hydrogen, and other new technology projects, you need to fully understand tax equity market conditions and the new structures coming to the fore.

Infocast, in organizing Tax Credits & Transferability 2024: Optimizing Post-IRA Opportunities, has brought together the markets’ leading practitioners, sponsors, and investors to get attendees 100% up to speed on today’s most important issues in this exceedingly dynamic space. You will get critical insights on the development of the transfer market, how to best meet and document compliance with new domestic content, PWA, and energy community requirements, and the ins and outs of tapping into funding through 45Q, 45V, 45X, and 45Z credits, and more.

No other event can provide you with the type of deep dive — guided by active market players — that you will find here into the following essential topics:

• Emerging Structures for Post-IRA Tax Equity and Transferability Transactions—Traditional, T-Flip, and Transfer Deals
• Building Tax Credit Transferability Deal Flow—Roles of Banks, Brokers, Platforms, and Other Players
• Negotiating Post-IRA Deals Incorporating Tax Equity—Strategies for New Risk Allocation and Assignment Concerns
• Methods of Incorporating Depreciation, Step-ups, and Other Financial Issues in T-Flip Structures
• Optimizing the Tax Benefits and the Capital Stack: What Are We Seeing in Hybrid/T-Flip and Transferability Transactions?
• Tax Credit Buyers’ Perspectives on Renewable Energy Tax Equity Deals
• Insurer Perspectives on Mitigating and Indemnifying Risks in Tax Credit Transfer Deals—Where Is the Market Headed?
• Developer and Project Sponsor Perspectives on Making Tax Equity and Transfer Deals