Maximizing ITC Value Through Third-Party Ownership Structures

Description

Third-party ownership can help ESCOs and their customers incorporate ITC-eligible technologies into ESPC projects when tax appetite, elective-pay timing, or capital constraints affect project economics. This educational session will compare partnership flip, lease pass-through, service-agreement, energy-as-a-service, and hybrid structures and explain how ownership, EPC terms, eligible basis, credit monetization, and compliance responsibilities must align.

Presenters:

Josh Howes, CEO, Walker Blue and Charlie Lord, Co-founder & Principal, Renew Energy Partners

Learning Objectives:

1. Identify when third-party ownership may improve the economics and deliverability of an ESPC project compared with customer ownership, elective pay, direct use of the credit, or credit transfer.
2. Compare partnership flip, lease pass-through, service-agreement, energy-as-a-service, and hybrid structures and explain how each allocates ownership, tax benefits, performance obligations, and risk.
3. Evaluate how ITC eligible basis, cost allocation, depreciation, prevailing wage and apprenticeship, domestic content, energy-community eligibility, and foreign-entity restrictions affect projected credit value.
4. Recognize common misalignments among EPC contracts, financing documents, service agreements, and tax-credit strategies that can delay closing or impair credit defensibility.
5. Apply a development-to-filing framework that assigns stakeholder responsibilities and sequences diligence, construction documentation, placed-in-service evidence, pre-filing registration, and tax filing.

NAESCO has submitted this webinar to the AIA for 1 CEU approval. 

NOTE: Beginning in 2023, all NAESCO webinars will be offered to all attendees at no cost. Recordings and slides will be available to members only, after the webinar.