Section 6418 is the IRA rule that makes certain clean energy tax credits transferable, meaning the project can sell the credit for cash to an unrelated buyer with tax capacity. The seller makes a transfer election on its tax return, the buyer pays cash, and the buyer claims the credit on its own return, with the IRS registration and documentation doing most of the heavy lifting. You cannot re-sell the same credit again, and the market lives and dies on eligibility, basis support, recapture exposure, and who writes the indemnity. Net, 6418 turns tax credits into a finance product, simpler than tax equity structurally, still not simple operationally.
Tax-Equity & Back Leverage Model Download EB Template
Project Waterfall v1.0
Whiteboard logic conversion: follow the money or lose it.
Green = inputs
Core Inputs
Pre Split Tax Alocation
5-Year MACRS Depreciation Table
Read only schedule based on depreciable basis
10-Year Cash Flow Table
Flip begins in Year 7
| Year | Phase | Outflow | Revenue | Opex | Avail Cash | Inv CF | Sponsor CF | Inv ITC (99%) | Tax Shield | Investor CF |
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Year 1 Cash Flow Snapshot
Pre-Flip economics at end of Year 1
| Waterfall Step | Ratio (S/I) | Sponsor ($) | Investor ($) |
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