Insights

A federal court vacated IRS Notice 2025-42 yesterday, restoring the 5% safe harbor as a valid method for wind and large-scale solar developers to establish beginning of construction — just 27 days before the July 4 deadline.

This guide focuses on tax equity bridge loans (TEBLs): their structure, cost, capital providers, and how the One Big Beautiful Bill (OBBB) has changed the landscape. 

This guide examines structural risk in tax credit transactions: what it is, how it arises, and how buyers and investors apply legal diligence and market-standard protections to mitigate risk and transact with confidence.

This guide examines placed-in-service risk in transferable tax credit transactions: what it is, how it arises, and how tax credit buyers and investors apply standardized due diligence to mitigate risk and transact with confidence. 

Four leading practitioners from KPMG, Novogradac, Holland & Knight, and Aon share how the PFE compliance market is taking shape as guidance continues to evolve.

Eligibility risk is the risk that the IRS disallows a claimed tax credit because the project doesn't meet statutory requirements — this installment of Crux's underwriting risk series covers how it arises across ITCs, PTCs, and bonus adders, and how buyers mitigate it.

See how 27% of Fortune 1000 companies used tax credits to lower their effective tax rates in 2025 — broken down by sector and company size.

This installment of Crux's underwriting risk series explains what recapture risk is, how it can be triggered, and how buyers and investors mitigate it through due diligence, indemnities, and insurance.

A February 2026 survey of clean energy developers and permitting professionals offers a clear picture of how federal permitting is shaping — and in some cases, stopping — clean energy project development.

Many individuals are interested in participating in the market for clean energy tax credits, both to invest in sustainable energy and manage federal taxes. While individuals can participate in the market, that opportunity is currently limited.

The EPA finalized higher-than-proposed renewable volume obligations for 2026–2027, signaling continued support for clean fuels. Here's what it means for RNG, renewable diesel, SAF, and ethanol producers.

This ultimate guide to transferable tax credits explains everything developers, tax credit buyers, and intermediaries need to know about transferability.

Learn how basis risk arises in tax credit transactions and how buyers and investors mitigate it through due diligence, indemnification, insurance, and pricing adjustments.

Crux's 2025 Market Intelligence Report reveals a maturing transferable tax credit market — and a narrowing window for buyers looking to secure 2025-vintage credits at favorable prices.

Crux's 2025 Market Intelligence Report reveals a resilient but increasingly selective market — and a shifting landscape for project finance debt.

Jim Alderson-Smith, Managing Director of Crux's Industry Coverage team, breaks down what clean energy developers and manufacturers should take away from 2025 and what he's tracking in 2026.

Crux convened an expert panel to unpack Treasury's interim PFE guidance. Here are the top takeaways

Crux Director of Research Katie Bays unpacks the key findings from the 2025 Market Intelligence Report, from record tax credit transfer volumes and the rise of hybrid tax equity to the policy headwinds facing fuels and manufacturing.

This guide outlines the most common tax credit transaction risks buyers face and the practical steps used to mitigate them.

Understand Notice 2026-15, which provides interim guidance on the prohibited foreign entity provisions enacted in the One Big Beautiful Bill last July.

The US Department of the Treasury and the IRS released proposed regulations implementing the §45Z clean fuel production credit as amended in last year's One Big Beautiful Bill.

Crux's debt capital markets and industry coverage teams share insights on 2025's lending environment and what developers need to know about FEOC compliance, debt-tax credit coordination, and accessing capital in 2026's market.

With tech giants turning to nuclear power for AI data centers, the §45U tax credit has become one of the most active segments in the clean energy tax credit market—here's what investors need to understand about pricing, eligibility, and market dynamics.

Crux's Tax Investor Coverage team shares insights on tax credit market trends and practical advice for corporate tax teams planning their 2026 strategies.

Explore the corporate alternative minimum tax and how corporate tax teams can leverage clean energy tax credits to help offset CAMT liability.

Learn how equipment financing helps clean energy developers secure capital, manage procurement risk, and meet tax credit deadlines.

Explore trends in tax credit insurance, including pricing and insurance prevalence across different tax credit categories.

Crux Research & Policy Strategist Katie Bays discusses key findings from Crux's recent FEOC industry preparedness market survey.

Crux's new tax credit transfer agreements (TCTAs) establish a common framework for transferable tax credit transactions, streamlining the process for transacting parties.

This guide walks through the mechanics of tax credit bridge loans, from structure and pricing to lender expectations and repayment dynamics. It’s designed to help developers and manufacturers understand when bridge financing makes sense and how to position projects for successful execution.

Highlights from Crux's recent briefing for lenders on the state of clean energy project finance.

Find out how clean energy tax credit insurance works, what it covers, and how sellers can use it to reduce risk and attract high-quality buyers.

Discover the criteria lenders use to evaluate clean energy projects, plus guidance for developers to improve bankability and secure better financing terms.

Dig into market data showing how changes to corporate tax liability affected pricing for investment and production tax credits in the third quarter of 2025.

Project finance lending to clean energy technologies makes up a significant — and growing — share of total project finance lending. Explore the trends shaping this market in 2025.

Kate is a seasoned fintech executive and trusted strategic advisor with more than 15 years of leadership experience in financial services.

Battery storage credits are growing fast. Dive into BESS project pricing, deal structures, and merchant risk in 2025's evolving tax credit market.

Find out how clean energy project finance works, along with strategies developers can use to secure capital and close deals in today’s shifting market.

Key lessons from our first 100 transactions across transferable tax credits, debt, and tax equity that are shaping how we build the infrastructure for clean energy finance.

Key terminology to help tax credit buyers and sellers negotiate tax insurance policies with confidence.

Answers to tax credit buyers' frequently asked questions about legacy tax credits and the switch to the technology-neutral tax credit regime.

The government shut down on October 1. Here's what that means for clean energy developers and corporate tax credit buyers.

Since the passage of the One Big Beautiful Bill, many market participants have wondered how the legislation will affect demand for transferable tax credits. To answer that question, Crux talked to experts at major accounting firms.

Announcing Document Intelligence, an automated capability that leverages large language models (LLMs) to identify and surface the critical details that matter most in clean energy transactions.

Crux's 2025 mid-year report highlights key trends shaping clean energy finance across tax credit transfers, tax equity, and lending.

Recently issued guidance from the Treasury Department offers clarity on safe harboring requirements for wind and solar developers. Here's what developers need to know.

Analysis of new guidance from the US Department of the Treasury regarding the beginning of construction for wind and solar energy projects.

Learn more about the current state of capital availability for clean energy and manufacturing projects, based on findings from Crux's survey of project finance lenders and investors.

What the newly passed One Big Beautiful Bill Act means for tax credit buyers — and how to prepare for a competitive second half of 2025.

The market for §45Z clean fuel production credits is in its early stages. Learn what buyers should know about this newly eligible technology and its growing role in the transferable tax credit market.

Crux's new diligence verification tool streamlines the once-manual and time-consuming process of organizing and reviewing diligence materials, saving time and effort for all parties in a transaction.

Key takeaways from our 2Q2025 Market Update, available exclusively to Crux clients and partners.

Key takeaways for clean energy and manufacturing tax credits in the tax and spending legislations passed by the Senate on Tuesday, July 1. The bill now returns to the House of Representatives.

Alisha Soares, senior vice president in the transactional risk practice at Marsh, chats with Crux about Marsh’s insights on the tax credit insurance market and how buyers can leverage insurance to mitigate risks, including the possibility of a change in tax law. 

Key takeaways from the Senate Committee on Finance's draft legislation released on June 16, 2025.

Participants in the transferable tax credit market and tax equity investors can contribute to Crux's industry-leading surveys.

In an increasingly competitive tax credit market, developers who are prepared to transact can set themselves up for a more successful, streamlined process. This article covers four elements that developers should consider as they prepare for their first transaction.

Proposed changes to the treatment of energy tax credits under international tax policy in the One Big Beautiful Bill Act risk upending investments in clean energy and manufacturing. This article explains the proposed changes in Section 899 and what their impact could be.

In this episode of Crux Connects, Mathew Loving, associate director with Schneider’s tax credit investment team, joins Crux to talk about Schneider’s unique experience as a buyer, how it informs their view on the transferable tax credit market, and the company’s advice to other tax credit buyers in 2025.

The IRS introduces a new elective safe harbor for clean energy project developers to demonstrate compliance with the domestic content bonus adder, which offers an additional 10% bonus on the value of their tax credits. 

Read key takeaways from our inaugural report on the market for lending in energy and manufacturing projects, covering the availability of capital for different technology types, trends in costs of capital throughout the development cycle, and the outlook for project finance lending in the future.

Buying clean energy tax credits can provide a range of benefits to corporate taxpayers. This guide covers the basics for companies interested in purchasing transferable tax credits.

Sam Kamyans, a partner in the Tax Practice Group at Kirkland & Ellis, joins Crux to discuss the implications to clean energy and manufacturing tax credits of the One Big Beautiful Bill Act passed by the US House of Representatives.

Key takeaways from the latest legislation out of the House, and what is expected as it moves to the Senate.

The §45X production tax credit (PTC) is a tool to accelerate necessary investments in extracting and processing America’s critical minerals. Learn about this newly eligible technology and its role in the transferable tax credit market.

Read our update and key takeaways from the proposed tax legislation introduced by the House Committee on Ways and Means on May 12, 2025.

As the transferable tax credit market grows more competitive, sellers must stand out. There are common actions every project developer and manufacturer can take to make their credits more appealing, ultimately generating more bids and maximizing their value. 

Three highlights from Crux's recent market and policy briefing for tax credit buyers.

Crux’s new Term Sheet Builder helps tax credit buyers and sellers align on key terms and close transactions with greater efficiency and transparency.

Get highlights from Crux's quarterly market update, based on $30 billion in tax credit transaction data.

We are thrilled to announce that Crux has successfully closed a $50 million Series B funding round, led by Lowercarbon Capital. This brings Crux’s total funding to over $77 million and marks a pivotal moment in our journey to transform capital markets for the clean economy.

This guide examines the differences between tax equity and transferable clean energy tax credits, including the rise of hybrid tax equity structures that utilize elements from both financing structures. 

Advanced manufacturing tax credits are among the most in-demand in the tax credit market. Learn what you need to know about these popular credits in this guide.

Crux’s data suggests that transferable tax credit buyers who transact earlier in the year can take advantage of wider tax credit credit availability as well as more potential for pricing discounts.

Beginning in 2025, clean energy projects have access to the new §48E clean electricity investment tax credit and §45Y clean electricity production tax credit. Going forward, developers of new projects need to understand the details of the new tax credits, and tax credit buyers should understand the different qualification parameters under the tech-neutral tax credit regulations.

Crux CEO and co-founder Alfred Johnson sat down with a panel of experts to discuss clean energy debt financing markets, including the current state of the market, the cost of capital, and more.

Transferability has created new and more accessible ways for more developers and manufacturers to monetize tax credits. With the emergence of transferability and the growth of this liquid and transparent transferable tax credit market, new financing structures have emerged.

§45X advanced manufacturing tax credits are a valuable new incentive for domestic clean energy manufacturers. Learn how to make the most of these incentives through the transferable tax credit market. 

As tax credit buyers begin to plan their 2025 strategies, one question keeps coming up: how will policy changes affect the transferable tax credit market? Brandon Hill, tax principal and leader of CLA’s Energy Tax Services, joined Crux to discuss how CLA is advising tax credit buyers in 2025.

Crux's debt capital solution enables developers and manufacturers to access a range of debt products — including bridge loans, construction financing, senior notes, revolver facilities, and more — alongside our powerful tax credit marketplace.

Since transferable tax credits started transacting in 2023, the market has matured rapidly. One indication of maturity is the strong pricing signals the market observed for clean energy tax credits, signaling market confidence and strong demand among tax credit buyers. But what drives tax credit deal pricing?

Read the highlights from Crux's annual market intelligence report, including the 2024 transferable tax credit market, emerging market standards, trends in energy and manufacturing project finance, and Crux's 2025 market outlook.

John Hensley, SVP markets and policy analysis for the American Clean Power Association (ACP) joins Crux to discuss ACP's recent report on the benefits of clean energy tax legislation. They discuss the methodology behind the report, the findings, and the benefits of transferability across sectors and regions.

All market participants are welcome to participate in Crux's ongoing data collection, which will enable us to share additional data offerings, real-time reports, in-depth white papers, and new platform tools.

The US Department of the Treasury released final guidance on the tech-neutral tax credit regime that took effect on January 1, 2025. Crux breaks down key takeaways from the final rules as well as how they differ from the proposed rules.

Orrick's John Eliason, a premier tax partner who advises investors and developers, and Alejandra Garcia Earley, an accomplished tax equity finance and tax credit purchase lawyer, join Crux to discuss the primary factors that tax buyers need to know about residential solar energy tax credits.

Learn the key differences between investment tax credits and production tax credits in this comprehensive guide. Understand how these tax credits work, eligibility requirements, and more.

Transferability is driving the domestic energy and manufacturing renaissance. Consumers and businesses all across America benefit from this key innovation, which is making energy more affordable and abundant and securing our supply chains for generations to come.

Crux is launching the Transaction Hub, a centralized place for developers and manufacturers, tax credit buyers, and advisors to manage, track, and execute transferable tax credit transactions.

Crux co-founder and CEO Alfred Johnson sat down with a panel of energy, tax, finance, and legal experts to discuss how tax reform under the next administration will likely impact energy tax credits.

The market for energy and manufacturing tax credits has seen immense growth in 2024, leading to increased competition. Sellers have more choices, so standing out is imperative for tax credit buyers. Crux has identified several ways that buyers can help differentiate themselves and win in a competitive process.

Summarizing the final guidance from the Treasury for 45X advanced manufacturing PTCs. The final guidance should simplify the process for US manufacturers and producers of critical minerals to access 45X tax credits. 

Download Crux's third quarter market update to obtain updated tax credit pricing by technology type, details on market supply, demand, and our outlook for the rest of 2024. 

Experts from the law firm Vinson & Elkins partnered with Crux to prepare a detailed guide to the IRS's pre-filing registration portal. Learn how to access the portal to register transferable tax credits generated by eligible projects and facilities, as well as how to properly account for transfers in the context of tax filings. 

On September 18 the IRS published proposed regulatory guidance addressing outstanding questions related to the 30C alternative fuel vehicle refueling tax credit. 

Crux is launching the Cruxtimate, projected market prices for clean energy tax credits. The Cruxtimate is derived from a model that takes into account a dozen factors that influence tax credit pricing. 

Two years ago, federal tax policy kicked off a wave of new investment in clean energy and domestic manufacturing supply chains. We highlight 10 important milestones that the clean energy sector has achieved since the passage of the law. 

Biofuel projects are newly eligible for federal clean energy tax credits and poised to comprise a growing share of the market.

Takeaways from Crux's Mid-Year market report, derived from $6.8 billion in reported transactions in 2024 tax transferable tax credit deals.

Crux surveyed three dozen leading tax, legal, and financial advisors and insurers. The white paper, based upon their feedback, details the emerging standards and practices for transactions in clean energy tax credits.