Infocast Solar + Wind Finance & Investment Summit 2026 Soundbites: Tax Credits, Tax Credit Insurance, the Market Tax Investors, FEOC and PWA

The Infocast Solar + Wind Finance & Investment Summit took place March 15–18, 2026 at the Arizona Biltmore, drawing approximately 3,700 attendees. This is the first of two blog posts with soundbites from panelists at the conference.

The soundbites below are drawn from select panels covering tax credit pricing and market conditions, tax equity dynamics, tax credit insurance, FEOC (foreign entity of concern) compliance, bonus depreciation, and PWA (prevailing wage and apprentice) requirements. The second post will be available in a week and will address the M&A market and general trends in the renewables power market.

Tax Credit Pricing and Market Conditions

Panelists from tax credit intermediaries, advisors, and investors addressed the post-OBBB (One Big Beautiful Bill) decline in tax credit pricing, the divergence in pricing between legacy and tech-neutral credits, the emergence of new tax credit types, and the outlook for a recovery in the tax credit market. 

On tax credit pricing trends and market structure: 

"Corporate tax appetite dropped significantly due to the OBBB. Demand in total has been reduced. There's more supply so pricing has decreased. There are billions of dollars of legacy Section 48 credits, and those are more attractive than credits subject to the FEOC rules." — Principal, Tax Advisory Firm

"There was some number of sellers that did not like the pricing in 2025 and have held on to their vintage 2025 credits to sell in 2026 before filing their 2025 tax returns." — Chief Executive Officer, Tax Credit Marketplace

"The market shock in 2025 brought new buyers to the table. They are looking for the lowest risk credits. We are seeing a divergence in pricing between high-quality and low-quality credits." — Partner, Tax Credit Advisory Firm

"The 2026 tax credit market is largely recovered. The R&D expensing was really a one-year thing. But we still aren't seeing pricing where we saw it in the first half of 2025." — Partner, Tax Credit Advisory Firm

"There has been a decrease in tax capacity as a result of the OBBB. There are more corporate buyers entering the market every year. We have observed a decrease in pricing across the board. That lower price will accelerate the corporates that come into the market. I don't think we will see a rebound to last year's pricing this year, but maybe late next year." — Managing Director, Tax Equity Advisory Services

"There is $400 billion of corporate tax appetite each year." —Executive, Preferred Equity Provider

"170 gigawatts (GWs) safe harbored by some means. 70 GWs of that is legacy Section 45 and 48 credits." — Chief Executive Officer, Tax Credit Marketplace

"Brownfield is a unique facts-and-circumstances determination. In some instances, we've been comfortable and in other instances not." — Managing Director, Regional Bank

On legacy versus tech-neutral credits: 

"Legacy credits are trading at a one to two cent premium versus tech-neutral credits." — Chief Executive Officer, Tax Credit Marketplace

"Most taxpayers want to focus on legacy Section 48 credits, so there is a fair amount of section 48E credits that are looking for a home." — President, Tax Credit Intermediary 

"There is a level of ITC fatigue out there. Now, there are 45Z [(clean fuels tax credit)] and 45X [(manufacturer's tax credit)] credits as alternatives that aren't much more expensive than ITCs and don't have the recapture and tax basis issues that the ITC does." — President, Tax Credit Intermediary

"We have seen 45Z bubble up to the top of the tax credit transfer market. We are seeing 45Z being favored, almost more than 45X." — Partner, Tax Credit Advisory Firm

"There hasn't been enough price elasticity in this market for buyers to take the time to learn about a new type of tax credit." — Managing Director, Global Asset Manager

"There has been an uptick from corporate buyers in production tax credits (PTCs) because they are perceived as less risk without recapture or basis step-ups. There are fewer PTC buyers in the market than ITC buyers." — Managing Director, Tax Credit Intermediary 

On investment grade tax credit sellers and ITC pricing:

"We do more deals that don't have insurance than do. If the seller is investment grade, buyers will pay more than for an insured deal. Those deals are perceived as less risk and simpler. The investment grade seller gets one to two cents higher price than an insured deal." — President, Tax Credit Intermediary

"94 cents for ITCs is the high end of the range." — President, Tax Credit Intermediary

"There are two markets. The first market is investment grade sellers and PTCs, and the second market is higher risk credits." — Chief Executive Officer, Tax Credit Marketplace

"The buyer universe is weighted towards investment grade sellers, but the growth is with non-investment grade sellers. Tax credit insurance is like a synthetic investment grade wrap." — Managing Director, Global Asset Manager 

On tax credit sales and market participation: 

"There have been positive developments on Pillar II [(a global top-up tax that was keeping some multinationals out of the tax equity market)] and that favorable guidance has led to more multinationals entering the tax credit transfer market." — Managing Director, Tax Equity Advisory Services

For background on Pillar Two — the Organisation for Economic Co-operation and Development's (OECD's) global minimum tax standard — see: Transferable Tax Credits Treated Favorably Under the OECD’s Pillar Two

Tax Credit Transfer Strategies and Tax Credit Price Floors  

Panelists from major tax equity investors and advisory firms addressed the mechanics of hybrid structures, the emergence of price floors in tax credit transfer deals, and bridge loan conventions.

"Tax credit transfer is a multi-tool." — Partner, Global Law Firm

"We go into deals with the intent to sell down, and in some instances, we decide to sell down after the fact. This is due to variability in our tax capacity and variability in the tax credit market." — Managing Director, Super Regional Bank

"Floors are something tax equity investors, as a partner in a hybrid partnership, offer — not preferred equity partners." — Partner & Managing Director, Tax Credit Intermediary

[A hybrid partnership is a partnership between a sponsor and tax equity investor in which of the tax credits are actually allocated to the tax equity investor and some are sold. Since the tax equity investor has its own tax appetite, it can provide a floor for the price the ITC will be sold for and claim the credits itself if it must (but with the hope the credits are sold for more than the floor price allowing it to conserve its tax appetite).]

"For the vast majority of tax credit transfer deals we see, the preferred partner does not provide the sponsor with a floor price for the sale of the tax credits. With a preferred equity partnership, you are not going to get a floor." — Partner & Managing Director, Tax Credit Intermediary

[This is because preferred equity partners generally do not have tax appetite to use the tax credits against because if they did they would be tax equity investors.]

"We are seeing many transactions with a floor." — Managing Director, Super Regional Bank

"A floor on the tax credit transfer price will reduce the cost of your tax credit bridge loan." — Managing Director, Global Investment Bank

"Just a few years ago there was no such thing as an uncommitted tax credit bridge loan. The bridge loan lender's expectation is that it is repaid at substantial completion either by tax equity capital contributions or tax credit transfer proceeds." — Partner & Managing Director, Tax Credit Intermediary

"The earlier in the year you want to get paid for your tax credit transfer the more of a discount there will be in the price." — Partner & Managing Director, Tax Credit Intermediary 

Bonus Depreciation 

Panelists addressed the practical tensions that bonus depreciation creates for corporate tax capacity and the strategic choices sponsors and investors face when structuring deals around depreciation elections.

"We see bonus depreciation from time to time but the most common is 5-year MACRS." —Executive, Tax Credit Facilitator

"Bonus depreciation negatively impacts the tax capacity of corporates." — Managing Director, Super Regional Bank

[This is because significant tax appetite is required to use bonus depreciation and that tax appetite could otherwise be used for tax credits.]

"It is difficult to get your tax department to elect out of bonus, even though we know it lets us do more tax credit deals." — Managing Director, Regional Bank

"With preferred equity partnerships, the preferred investor does not value depreciation. So, we elect bonus depreciation and allocate 99% of it to the sponsor to offset the tax gain on the FMV sale." — Partner & Managing Director, Tax Credit Intermediary 

Tax Credit Insurance 

Panelists from major insurance brokers and advisors addressed the tightening insurance market — rising premiums, new exclusions, a shortage of carriers, and the growing role of insurance as a tool for non-investment grade sellers. One major insurance broker reported writing $9 to $10 billion in limits of tax credit insurance policies in 2025. 

On the state of the tax credit insurance market: 

"Less than 18% of tax credit insurance policies ever have a claim against them — and that doesn't mean those are even full claims." — Senior Vice President, Insurance Broker

"Premiums are 3 to 5%, up from 2 to 4%. The markets have gotten tighter and pickier about what type of risk they want to cover." — Senior Vice President, Insurance Broker

"It is interesting to see premium pricing go up while underwriters’ risk aversion also goes up. In most capital markets, when pricing increases, risk aversion decreases." — Managing Director, Global Asset Manager

"A new tax credit insurance carrier entered the market today, but the new carriers are not entering the market fast enough to keep up with the demand. New exclusions in tax credit insurance policies make insurance not the complete mitigant it used to be." — Partner, Tax Credit Advisory Firm

"There is a renewed focus on the strength of the balance sheet that is covering gaps in tax credit insurance policies." — Partner, Tax Credit Advisory Firm

On insurance as a tool for non-investment grade sellers: 

"Tax insurance is helping deals get done for non-investment grade sellers." — Executive Vice President, Tax Insurance Broker

"Corporate tax departments are trained to avoid risk. We have actually seen more transactions not have insurance than in the past." — Managing Director, Tax Equity Advisory Services

"We generally require insurance for ITC step-ups. If the sponsor is taking a unique approach on adders, we'll say we'll consider it with insurance and a ‘should’ tax opinion from the sponsor's counsel." —Executive, Tax Equity Investor 

On letters of credit as an alternative: 

"If insurance is expensive, a letter of credit to back an indemnity is far more expensive." — Principal, Tax Advisory Firm

"It becomes very expensive to use a letter of credit to backstop an indemnity." — Partner, Tax Credit Advisory Firm 

FEOC (Foreign Entity of Concern) Compliance 

Panelists from banks, advisors, and investors addressed the pervasive uncertainty created by the FEOC rules — with little consensus on when guidance will arrive, what it will say, or how the market should respond in the interim. 

On the scope and complexity of FEOC: 

"I don't think you can overstate how complicated FEOC can be. The rabbit hole can go so deep for the work you have to do to demonstrate compliance. The sellers of tax credits will need to provide broad reps on FEOC." — Managing Director, Tax Equity Advisory Services

"There is no easy way to deal with FEOC. Treasury has provided one-third of the FEOC guidance needed, and the FEOC guidance we have on ‘material assistance’ [(i.e., the restrictions on the percentage of Chinese equipment)] is more relevant a year from now." — Director, Agricultural Lender

[It is more relevant a year from now because if a project “began construction” before the end of 2025, then it is grandfathered from the material assistance rules. Therefore, next year we will see more projects subject to material assistance.] 

On the market response to FEOC uncertainty: 

"We just want clarity. We aren't directly lobbying the government about FEOC. We think that's a job for the industry. We don't know what the term “prohibited foreign entity” means yet, and that is a problem for our sponsors." — Managing Director, Super Regional Bank

"We are deferring on going to market with 48E credits until there is clarity." — Partner & Managing Director, Tax Credit Intermediary

"The heart of the issue is the specified foreign entity (SFE) rules. We have a whole vintage grandfathered project that began construction in 2025 for which the FEOC material assistance rules matter not. We are working feverishly on what SFE means at our bank." — Managing Director, Regional Bank

"We've seen one report that 33 gigawatts (GWs) are grandfathered under 48, and we've seen another report that 70 GWs are grandfathered under 48. That's where the tax equity market is going to go." — Managing Director, Super Regional Bank

"Proposed FEOC regulations are expected in May or June — but no one knows." — Partner, Tax Credit Advisory Firm

On legacy credits as a FEOC workaround:

"There are billions of dollars of legacy Section 48 credits, and those are more attractive than credits subject to the FEOC rules." — Principal, Tax Advisory Firm

"Most taxpayers want to focus on legacy Section 48 credits, so there is a fair amount of Section 48E credits that are looking for a home." — President, Tax Credit Intermediary 

Prevailing Wage and Apprenticeship (PWA) Requirements

Projects over one megawatt are required to pay construction workers on the project site at least the prevailing wage established by the Department of Labor and to involve apprentices in the construction or else the tax credits are one-fifth of what they would otherwise be.

"PWA is workable." — Managing Director, Regional Bank

"PWA is a very well-established process as to what reports are required from the consultants." — Managing Director, Global Investment Bank

"PWA is curable, and that's a big deal." — Partner & Managing Director, Tax Credit Intermediary

[What this refers to is that if there is a PWA compliance misstep it can be corrected by making cure payments with interest to the workers paid less than prevailing wage and paying a penalty to the IRS, rather having the tax credits be one-fifth of what was expected (e.g., 6%, rather than 30%). ]