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

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

Direct Pay for Schools: How Tax-Exempt Districts Turn Clean-Energy Tax Credits Into Cash

Direct Pay for Schools: Fund Clean Energy With Tax Credits

By John Kapral, CPA – Senior Director, Renewable Energy Tax Incentives and Credits, Walker Blue The short version. Direct pay, formally called elective pay, lets a public school district receive the value of a federal clean-energy tax credit as a cash payment from the IRS, even though the district owes no federal income tax. On … 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

Can District and Campus Geothermal Projects Qualify for the Federal ITC?

Campus geothermal energy system showing underground heat exchange loops serving multiple educational buildings, illustrating how district and campus geothermal projects can support sustainability goals and potentially qualify for federal clean energy tax incentives.

Yes, geothermal systems serving district energy networks, campuses, and central plants may qualify for the federal Investment Tax Credit, and the runway is longer than most owners assume. While solar and wind face compressed construction-start timing under the One Big Beautiful Bill Act (P.L. 119-21, enacted July 4, 2025), geothermal heat pump property retained eligibility … 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

Aggregation Rules Under Section 48E: Implications for Common Owners of Multiple Clean Electricity Properties

The Inflation Reduction Act of 2022 introduced the Section 48E Clean Electricity Investment Credit (the “48E Credit”), a technology-neutral investment tax credit that largely replaced the legacy Section 48 energy credit for qualified facilities and energy storage technology (EST) placed in service after December 31, 2024. While many taxpayers and advisors are familiar with the … Read more

Case Study: Warren Woods Schools, Michigan, Solar Project Qualifies for $735K ITC

Walker Blue partnered with Warren Woods Public Schools to certify and maximize the Investment Tax Credit (ITC) for a solar energy project at Warren Woods Tower High School in Warren, Michigan.  The 300 kW AC roof-mounted photovoltaic (PV) system was installed in conjunction with a roof replacement project necessary to support the solar array. Of … Read more

Webinar: Energy Tax Incentives in 2026: Key Deadlines and Filing Traps CPAs Must Avoid

Energy tax incentives are appearing in more client filings than ever. In 2026, the biggest risks for CPAs are no longer eligibility questions, but missed deadlines, timing errors, and unsupported assumptions made under filing pressure. This webinar is led by David Diaz, Chief Strategy Officer at Walker Blue, and John Robinson, Executive Director, Residential Energy … 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

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