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

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

Project Labor Agreements in the Context of Section 48 and 48E Investment Tax Credits: Enhancing Compliance with Prevailing Wage and Apprenticeship Requirements

Executive Summary The Inflation Reduction Act (IRA) of 2022 has significantly expanded tax incentives for clean energy projects through enhancements to the Investment Tax Credit (ITC) under Sections 48 and 48E of the Internal Revenue Code. A key feature of these incentives is the opportunity for taxpayers to claim a fivefold increase in the credit … Read more

Case Study: Franklin County, Arkansas, Solar Project Qualifies for $188K ITC

Project Overview Franklin County Government developed a solar photovoltaic project at 1027 Marts Drive in Ozark, Arkansas. The project consists of a 292 kW AC solar ground mount PV system installed on county-owned property and placed in service in March 2024. Walker Blue was engaged to perform a full Investment Tax Credit (ITC) certification and … Read more

Provisions in the Section 48 and 48E Investment Tax Credits: Navigating Domestic Content Requirements for Elective Pay

Executive Summary The Inflation Reduction Act (IRA) of 2022 introduced transformative incentives for clean energy investments, including the Investment Tax Credit (ITC) under Sections 48 and 48E of the Internal Revenue Code. A key feature is the elective payment option, commonly known as “direct pay,” which allows certain entities—such as tax-exempt organizations, governments, and tribal … Read more

Why ITC Success for Geothermal and Storage Projects Is Won or Lost Before Construction Starts

For years, the Investment Tax Credit was treated as something handled after a project was designed, built, and placed in service. That approach no longer works. Under the Inflation Reduction Act and clarified further under OBBBA, geothermal and energy storage projects sit at the center of ITC opportunity. They also sit at the center of … Read more

Case Study: Texas High School Geothermal Project Qualifies for $10M ITC

Walker Blue, LLC, a specialized consultant in Investment Tax Credits (ITC) for clean energy projects, partnered with a large independent school district in Texas to optimize federal incentives for a groundbreaking new high school campus. The project incorporated an advanced geothermal heating, ventilation, and air conditioning (HVAC) system, qualifying for significant tax credits under the … Read more

Case Study: Kentucky High School Solar Project Qualifies for $126K ITC

Walker Blue was engaged to conduct a comprehensive Investment Tax Credit (ITC) eligibility assessment for a solar project at a high school in Kentucky. The public high school serves approximately 500 students in grades nine through twelve and functions as a central academic and community hub for the district. The facility operates year-round to support … Read more

Year-End Planning for Energy Tax Incentives: Deadlines That Matter Going Into 2026

As we close out the year, several energy tax incentive deadlines are approaching that deserve immediate attention. We are already seeing projects miss opportunities simply because planning started too late. The goal of this note is to highlight the timelines that matter most for ITC, 179D, and housing-related incentives, and to encourage early coordination so … Read more

Webinar: What Design Engineers Need to Know About the Investment Tax Credit (ITC)

January 22, 2026 – 2 PM EST REGISTER The Investment Tax Credit (ITC) has become one of the most valuable incentives driving energy efficiency and renewable energy projects under the Inflation Reduction Act, but many design engineers aren’t aware of how their work directly affects a project’s eligibility and credit value. Join Walker Blue for … Read more

Case Study: Michigan Middle School Solar Project Qualifies for $1.4M ITC

Walker Blue partnered with a Michigan school district to certify and maximize the Investment Tax Credit (ITC) for a solar energy project at a middle school. This initiative demonstrates how public institutions can leverage federal incentives under the Inflation Reduction Act to reduce energy costs, promote environmental stewardship, and enhance educational opportunities in STEM fields. … Read more

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