Geothermal ITC for ESCOs: Who Claims the Credit and How It Affects Performance Contracts

Geothermal ITC for ESCOs: Who Claims the Credit and How It Affects Performance Contracts

Diagram showing how ownership determines who may claim or monetize the geothermal ITC in an ESCO performance contract.

David Diaz, Chief Strategy Officer · Technical review: John Kapral, Senior Director, Renewable Energy Tax Incentives & Credits · Updated September 2026 At a Glance Question Short answer Primary credit Section 48 Potential rate 30% with applicable requirements; potentially up to 50% with qualifying adders Customer-owned public project Elective pay may be available under §6417 … Read more

The geothermal tax credit in 2026 and who can still claim it

2026 tax credit for a geothermal energy project showing drilling equipment and ground-loop installation at a commercial building.

One geothermal credit went to zero in 2025. The one that heats and cools buildings still runs through 2034 construction starts. By Josh Howes, CEO, Walker Blue Technical review by John Kapral, JD, CPA, LLM, Senior Director of Renewable Energy Tax Incentives and Credits Bottom line. Commercial geothermal heat pump projects may qualify for a … Read more

Case Study: How a $937,000 Geothermal Project Produced a $289,000 Federal Tax Credit

Henry County Board of Education | New Castle, Kentucky By David Diaz, CSO, Walker Blue LLC The Henry County Board of Education installed a 22.7 kW geothermal water-source heat pump system at a total project cost of $937,030. Walker Blue substantiated $851,157 as ITC-eligible basis and supported a federal Investment Tax Credit of approximately $289,000, … Read more

Alta Wind on Remand: A Practical Framework for ITC Eligible Basis After the July 8, 2026 Trial Order

Alta Wind on Remand: ITC Eligible Basis After the 2026 Order

By Josh Howes 1. Executive summary The U.S. Court of Federal Claims’ July 2026 trial order in Alta Wind I Owner Lessor C, et al. v. United States is already being characterized as a victory for cost-based renewable-energy valuation and a rejection of purchase-price or income-based basis. That description is directionally understandable but legally incomplete. … Read more

Walker Blue Supports Congressional Effort to Extend 179D and 45L Energy-Efficiency Incentives

Josh Howes, CEO Walker Blue, LLC Walker Blue, LLC, an engineering-led tax advisory firm specializing in clean energy and energy-efficiency incentives, voiced strong support for extending Section 179D, the Energy Efficient Commercial Building Deduction, and Section 45L, the New Energy Efficient Home Credit, beyond their scheduled expiration today. The statement follows a June 29 letter … Read more

Court Vacates IRS Notice 2025-42: Five Percent Safe Harbor Restored for Now

Court Vacates IRS Notice 2025-42: What Solar Developers Need to Know Before July 4

Industry Update — June 7, 2026 On June 6, 2026, the U.S. District Court for the District of Columbia vacated IRS Notice 2025-42 in full. Oregon Environmental Council v. IRS, No. 1:25-cv-04400 (CKK) (D.D.C. June 6, 2026), ECF No. 50. The Notice had eliminated the Five Percent Safe Harbor for establishing “beginning of construction” (BOC) for wind … Read more

Case Study: LEED EA Energy Modeling for a $90M Geothermal Central Plant: University of Louisville Speed School

Geothermal Central plant

30.1% Modeled Annual Utility Cost Reduction. 12 LEED EA Points Supported. 160 Geothermal Wells Drilled 600 Feet Deep. The University of Louisville’s J.B. Speed School of Engineering Student Success & Research Building is one of the more technically demanding LEED EA energy modeling engagements Walker Blue has completed for a higher education client. The $90 … Read more

A Rare Refund Opportunity: What the IEEPA Tariff Reversal Means for Energy, Manufacturing, and Infrastructure Clients

Overview There aren’t many situations where the government effectively says, “We’re giving the money back.” That’s what is now happening for certain importers. Following a recent Supreme Court decision, tariffs imposed under the International Emergency Economic Powers Act, or IEEPA, from 2025 through early 2026 have been struck down, and U.S. Customs and Border Protection … Read more

Walker Blue Awarded State of Utah Cooperative Contract for Clean Energy Tax Credit Consulting

Boca Raton, FL – Walker Blue, LLC has been awarded a State of Utah Cooperative Contract to provide Tax Consulting for Clean Energy Tax Credits to state agencies and eligible public entities. The contract is effective March 1, 2026, through February 28, 2038, and establishes Walker Blue as an approved provider of federal clean energy … Read more

Navigating Prohibited Foreign Entity Restrictions in Clean Energy Tax Credits: An Analysis of IRS Notice 2026-15

Executive Summary The One, Big, Beautiful Bill Act, which is commonly known as OBBBA and was enacted on July 4, 2025, introduced significant restrictions on clean energy tax credits under Internal Revenue Code Sections 45X, 45Y, and 48E to limit involvement from Prohibited Foreign Entities, or PFEs. IRS Notice 2026-15 provides interim guidance on these … Read more

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