Who We Serve · Solar Companies
Solar tax credits now run on documented dates.
P.L. 119-21 ended the homeowner credit, put a placed-in-service deadline on new solar projects and added foreign-sourcing rules that reach into your supply chain. A June 2026 court decision then reopened the beginning-of-construction rules. We help installers and developers prove eligibility, monetize credits and keep the cash cycle financed.
- Residential installers
- Commercial and industrial EPCs
- Small project developers
- Third-party-ownership channel partners
- Solar-plus-storage integrators
The financial shape of the business
Solar economics now depend on the calendar.
Three shifts define the operating environment for installers and developers in 2026.
01
The homeowner credit is gone
Section 25D no longer applies to expenditures made after December 31, 2025, so homeowners paying cash or financing a purchase lost the 30% federal credit. That shifts residential economics toward leases and PPAs, where the system owner can still claim §48E.
02
Eligibility is a documentation exercise
Whether a project began construction, when it was placed in service and where its components came from now decide whether it earns a credit at all. Those facts have to be provable from contracts, invoices, site records and supplier statements.
03
Credits are a financing asset
Developers without enough tax liability to use credits can sell them under §6418, bring in tax equity or sell through a third-party-ownership partner. Each buyer or partner runs its own diligence on the same eligibility record.
Tax Advisory
The provisions that decide whether a solar project earns a credit.
Current law under P.L. 119-21, the IRS notices that implement it, and the June 2026 court decision that changed the beginning-of-construction rules.
- The 2027 placed-in-service cliffWind and solar facilities whose construction begins after July 4, 2026 earn §48E or §45Y only if placed in service by December 31, 2027. Projects that began construction by July 4, 2026 are outside that cutoff and are measured instead against the continuity requirement. Energy storage is carved out of the wind-and-solar termination by §48E(e)(4)(C), so a battery at a solar site keeps its own credit path.1,4
- Beginning of construction after the Notice 2025-42 vacaturOn June 6, 2026 the U.S. District Court for the District of Columbia vacated Notice 2025-42 in full and remanded it to the IRS (Oregon Environmental Council v. IRS, No. 25-4400). With the notice vacated, the framework in Notice 2022-61 governs: the Physical Work Test or the Five Percent Safe Harbor, plus a Continuity Safe Harbor if the facility is placed in service within four calendar years after the year construction began. Because the IRS can still issue new guidance on remand, we build each project file to the physical work standard where the facts allow.5,6,7
- Prohibited foreign entity rules reach the bill of materialsFor facilities beginning construction after December 31, 2025, the credit is lost if the material assistance cost ratio — the share of manufactured-product direct costs not attributable to prohibited foreign entities — falls below 40% for construction beginning in 2026 or 45% in 2027; storage thresholds start at 55%. Notice 2026-15 provides interim safe harbors, including reliance on supplier certifications signed under penalties of perjury, until Treasury issues the safe harbor tables the statute requires by December 31, 2026. Errors in the determination keep the assessment period open for six years under §6501(o).1,8
- Selling credits under §6418A transfer must be paid in cash to an unrelated buyer; the proceeds aren’t income to the seller and aren’t deductible by the buyer. A partnership or S corporation treats the cash as tax-exempt income, shared in line with each owner’s share of the credit. Each credit property needs IRS pre-filing registration and its own transfer election on the return, and P.L. 119-21 bars transfers of these credits to a specified foreign entity.9,10,1
- The rate stack: 6%, 30% and the addersThe §48E base rate is 6%; it rises to 30% for facilities under 1 MW AC or that meet prevailing wage and apprenticeship rules. Prevailing wages apply to every contractor and subcontractor during construction and to alteration or repair for five years after placed in service, and qualified apprentices must perform 15% of construction labor hours on projects begun after 2023. Energy community and domestic content can each add 10 percentage points; the domestic content threshold is 50% for construction beginning in 2026 and 55% after.4,11,12
- §25D’s end and the leasing ruleHomeowners can’t claim §25D for systems whose installation was completed after December 31, 2025, even if the contract was signed earlier. Third-party owners of residential systems can still claim §48E, subject to the deadlines and sourcing rules above. The new §48E(i) leasing denial reaches leased solar water heating and small wind property, not solar electric systems.1,2,4
- Basis, depreciation and recapture on owned systemsSection 48E qualified property is 5-year property under §168(e)(3)(B)(viii), and 100% bonus depreciation applies to property acquired after January 19, 2025. Depreciable basis is reduced by half the credit under §50(c)(3). A disposition within five years recaptures the credit on a sliding scale, and a new 10-year recapture rule reaches payments that give a specified foreign entity effective control, for credits allowed in taxable years beginning after July 4, 2027.13,1,14
CFO Advisory
Finance the gap between install and cash.
Solar companies carry equipment, labor and permitting costs long before financing partners, utilities and credit buyers pay. We build the reporting that keeps that cycle funded.
| Metric | What it tells you | Cadence |
|---|---|---|
| Installed cost per watt by component | Modules, inverters, racking, labor, permitting and customer acquisition per watt installed. It is the base for pricing, partner rate cards and credit basis. | Per job · Monthly |
| Net revenue per watt after dealer fees | Contract price less lender dealer fees, holdbacks and partner discounts. Gross contract value overstates what a financed sale is worth to you. | Per job |
| Days from contract to install to permission to operate | Cycle time through permitting, installation and utility interconnection. Every stage is working capital, and for projects facing the 2027 deadline it is also credit eligibility. | Weekly |
| Cancellation rate by financing type | Signed contracts that never install, split by cash, loan and third-party ownership. It shows whether the post-§25D offer is holding. | Monthly |
| Placed-in-service runway | Each project’s expected placed-in-service date against December 31, 2027, with its beginning-of-construction evidence on file. A project that slips past the date loses the credit, not part of it. | Monthly · Per project |
| Material assistance cost ratio by project | The estimated ratio and the share of costs backed by supplier certifications. A ratio near the threshold needs sourcing decisions before procurement, not after. | Per project |
| Milestone receivables from partners | Amounts due from third-party-ownership funds and lenders at each project milestone, aged. Delayed milestone payments show up here before they show up in the bank balance. | Weekly |
| Credit monetization: price and days to cash | Transfer price per dollar of credit, buyer diligence costs and time from placed in service to payment. It belongs in every project’s cash forecast. | Per transaction |
Accounting & Compliance
What we run, and who we coordinate with.
We keep the records that prove credit eligibility and the books that support financing. Engineering, legal opinions, attest work and sales tax filings stay with specialists.
Handled by our team
- Beginning-of-construction files — binding contracts, invoices, cost incurrence and physical work evidence by project
- Prevailing wage and apprenticeship records — payroll data from you and every subcontractor, checked against the applicable wage determinations
- Material assistance workpapers — cost ratios and supplier certification tracking under Notice 2026-15
- §6418 transfer support — pre-filing registration, transfer elections and buyer diligence packages
- Form 3468 and basis schedules — credit computation, the 50% basis reduction and depreciation
- Job costing and partner billing — cost per watt and milestone receivables closed monthly
Coordinated with your specialists
- Independent engineers — placed-in-service and physical work determinations
- Tax equity investors, credit buyers and their counsel — diligence on eligibility and recapture
- Your audit firm — when lenders or investors require audited statements
- A sales and use tax provider such as Avalara or TaxJar — equipment exemptions vary by state
- Credit-insurance brokers — we supply the eligibility record; we don’t place insurance
What changed · What’s next
Dates that matter for solar companies.
Statutory deadlines under P.L. 119-21 and the guidance and litigation around them.
§25D ends; sourcing rules begin
Homeowner expenditures after this date earn no §25D credit, and facilities beginning construction after it are subject to the material assistance rules.1
Ahead
AheadPlaced-in-service deadline
Solar facilities that began construction after July 4, 2026 must be placed in service by this date to earn §48E or §45Y. Construction beginning in 2027 must also clear a 45% material assistance threshold.1
The Beaconshire Method
How an engagement runs.
Four phases, one accountable team. Tax, CFO and accounting work move together, so a decision made in one discipline is already reflected in the other two.
Phase 01
Discovery
We inventory your pipeline project by project — construction-start evidence, expected placed-in-service date, supplier sourcing, financing structure — and review how your books capture cost per watt and partner receivables.
Phase 02
Strategy
We decide which projects to accelerate, how to document beginning of construction, whether to transfer credits or bring in tax equity, and how project entities should be structured.
Phase 03
Implementation
We build the eligibility files, set up prevailing wage and sourcing tracking, register credits for transfer and prepare the credit and basis schedules for the return.
Phase 04
Stewardship
Monthly close and pipeline reporting, updates as Treasury issues safe harbor tables and further guidance, and recapture monitoring for five years after placed in service.
Run the numbers first
Where this work lives
Tax Advisory & Planning
Year-round planning, entity design and multi-year projections — scoped so the savings justify the fee.
Explore advisory →Fractional CFO
Forecasts, KPI dashboards, lender and board reporting, and a monthly close review.
Explore fractional CFO →Entity Formation
Entity choice, formation and tax elections set up together, for the result you actually want.
Explore formation →FAQ
Common questions.
We didn’t start construction by July 4, 2026. Is our commercial pipeline still eligible?
Yes, if each project is placed in service by December 31, 2027 and meets the prevailing wage, apprenticeship and material assistance rules that apply to it. A project that misses the date doesn’t get a reduced credit; it gets none. Storage is not subject to the wind-and-solar cutoff.
Does the Notice 2025-42 decision help projects we started in the first half of 2026?
It can. With the notice vacated, the earlier IRS framework applies, under which paying or incurring at least 5% of the facility’s total cost can establish beginning of construction for projects of any size. New IRS guidance on remand could change that, so projects relying on the 5% safe harbor should also be documented under the physical work standard where possible.
Can our residential leases still claim §48E?
Generally yes. The leasing restriction added by P.L. 119-21 applies to leased solar water heating and small wind property, not solar electric systems. The owner still has to meet the beginning-of-construction or placed-in-service deadline, the prohibited foreign entity rules and, at 1 MW AC or more, prevailing wage and apprenticeship.
What does a supplier certification need to contain?
Under the statute and Notice 2026-15, it must include the supplier’s EIN or a comparable foreign identification number, be signed under penalties of perjury, come from the supplier you bought from, and be kept by both of you for at least six years. You can’t rely on one you know, or have reason to know, is inaccurate.
How is cash from a credit sale taxed?
It isn’t income to the seller and isn’t deductible by the buyer. In a partnership or S corporation, the proceeds are treated as tax-exempt income, which increases owners’ basis in line with their share of the credit.
Do prevailing wage rules cover our subcontractors?
Yes. For projects that rely on prevailing wage and apprenticeship for the 30% rate, wages paid by you and every subcontractor on construction must meet the Labor Department rates for the locality, and alteration or repair work must meet them for five years after placed in service. The apprenticeship participation rule applies to each contractor or subcontractor with four or more workers on the project.
Other industries we serve
Sources
- [1]Public Law 119-21 (One Big Beautiful Bill Act), §§70301, 70506, 70512, 70513 — U.S. Government Publishing Office
- [2]26 U.S.C. §25D — Residential clean energy credit — Legal Information Institute, Cornell Law School
- [3]Issue Spotlight: Solar Financing (August 7, 2024) — Consumer Financial Protection Bureau
- [4]26 U.S.C. §48E — Clean electricity investment credit — Legal Information Institute, Cornell Law School
- [5]Oregon Environmental Council v. Internal Revenue Service, No. 25-cv-4400 (CKK), Memorandum Opinion (June 6, 2026) — U.S. District Court for the District of Columbia
- [6]Internal Revenue Bulletin 2022-52 (Notice 2022-61, section 5) — IRS
- [7]Notice 2025-42 (vacated June 6, 2026) — IRS
- [8]Notice 2026-15, Interim safe harbors for material assistance from a prohibited foreign entity — IRS
- [9]26 U.S.C. §6418 — Transfer of certain credits — Legal Information Institute, Cornell Law School
- [10]Treas. Reg. §1.6418-2 — Rules for making transfer elections — eCFR
- [11]26 U.S.C. §48 — Energy credit (prevailing wage, §48(a)(10); domestic content, §48(a)(12)) — Legal Information Institute, Cornell Law School
- [12]26 U.S.C. §45 — Apprenticeship requirements, §45(b)(8) — Legal Information Institute, Cornell Law School
- [13]26 U.S.C. §168 — Accelerated cost recovery system — Legal Information Institute, Cornell Law School
- [14]26 U.S.C. §50 — Investment credit recapture and basis rules — Legal Information Institute, Cornell Law School
Figures and deadlines verified October 23, 2026
Bring us your project pipeline.
We’ll review beginning-of-construction evidence, placed-in-service timing, sourcing and monetization plans project by project, and scope an engagement where the potential tax savings and financial clarity justify our fees. If we don’t believe the math works in your favor, we’ll tell you before you engage.
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