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Tax-Equity
Green Final
Term | Definition |
---|---|
Potential Tax Benefits Renewable Energy | PTC, ITC, Depreciation, Tax Credit Phase-outs |
Tax Equity financing structures | partnership flip structure, sale leaseback, inverted lease pass-through structure |
Depreciation incentives | 5-year MACRS, bonus depreciation |
When is ITC claimed | one time when project put into service |
Recapture risk | if there is a change in control with respect to interests held by party claiming ITC, recapture rate falls from 100% to 0% through 4 years |
When is ITC more valuable | projects with huge capital costs (such as offshore wind) or projects with low expected generation |
Why tax equity important | Special purpose entities may have no taxable income for years |
Partnership flip structure | Investor gets 99% of tax items until a certain IRR is reached then flips to 5%/95% with sponsor holding more now, cash is somewhat close to reverse but investor gets 100% in phase 2 |
partnership flip structure positive and negatives | explicit safe-harbor, mitigates tax risks, developers like it because inexpensive buyout and after flip date they are back to getting benefits, but it is not 100% efficient |
back-leverage recovery | can only foreclose upon sponsor's equity in the project, not the project itself |
Sale/leaseback structure | Once project is operational, developer sells to tax equity who then leases back to developer, which lets TE investor get 100% depreciation and tax credits while lessee manages project, then at end of life it goes back to investor unless buyout |
sale/leaseback good and bad | offers 100% financing for developer, 100% tax benefits gotten, but developer loses some control and tax equity more invested |
advantages of tax credit system | private investors more control in deciding which projects deserve subsidies, keeps subsidies domestic |
disadvantages of tax credit system | uncertainty due to constant changing of expiration dates, structures are complex and thus expensive, audit risks difficult to quantify, limited number of tax equity investor base |