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

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

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: Martin County High School, Kentucky, 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 public high school in Kentucky. Martin County 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

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