JOE-4Sun Citizens Enterprises Corporation
AshlandMA
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If the entity that is building the community solar system is not a taxable entity or does not have a sufficient tax liability, tax equity investment can be used to extend the tax liability of a third-party to the project. The taxable entity will make the investment to build the community solar array and will own that system for a period that allows for full asset depreciation (usually six years). The system is then transferred to the original system developer, less fees taken by the tax equity investor. In this way, the tax incentives can be monetized and reduce the cost of installation.
The passage of the Inflation Reduction Act in August of 2022 may impact the structure and financial returns of a tax equity investment. Non-taxable system owners should consider carefully if a direct payment option for the ITC, selling the ITC, or a traditional tax equity investment will provide them the most benefit in terms of financial returns, timing of payment, and transactional ease.
Congressional Research Service: Tax Equity Financing: An Introduction and Policy Considerations
Clean Energy FInance Forum: The Way Forward: Direct Pay and the Future of Tax Equity
