2025 Section 48E Tax Credits
$16 million of 2025-vintage Section 48E investment tax credits, available for transfer under Section 6418.
The credits are drawn from a portfolio of 890 residential solar and battery storage assets in Texas and California, available for transfer to a corporate buyer under Section 6418.
Credits Available
$16.0M
Available for transfer
Credit Vintage
2025
Section 48E investment tax credits
Transfer Mechanism
§6418
Credit sold for cash, separately from the projects
ITC Rate
40%
On 83% of assets
Asset Locations
TX · CA
Residential solar and battery storage
Project Size
< 1 MW
Every project — no prevailing wage & apprenticeship requirements
The Transaction
What the buyer receives
A federal investment tax credit, applied dollar-for-dollar against federal income tax in the credit year. Section 6418 lets the credit be sold for cash, separately from the projects that generated it.
- Transfers: the federal Section 48E credit, in cash, at close.
- Does not transfer: ownership, depreciation, operating cash, or any obligation to run the assets.
- Buyer profile: a corporation with federal income tax liability to offset.
Composition
Asset mix
| Type | Share of credit value |
|---|---|
| Storage (BESS-only) | 58.7% |
| Solar (PV-only) | 41.3% |
Credit Profile
Portfolio by ITC rate
| Rate | Share of assets |
|---|---|
| 40% base + adder | 83.1% |
| 30% base | 16.0% |
| 50% base + two adders | 0.9% |
Geography
Credit locations
| State | Share of credit value |
|---|---|
| Texas | 74.9% |
| California | 25.1% |
Broadly distributed across both states — no single city represents more than 9% of portfolio credit value.
Bonus Credits
Adder qualifications
| Adder | Share of assets |
|---|---|
| Energy community | 83.1% |
| Domestic content | 2.1% |
Process
Where this stands
| Item | Status |
|---|---|
| IRS pre-filing registration | In process |
| Tax opinion | In process |
| Target close | By Sept 15, 2026 |