Introduction to Tax Equity Structures – Part I
Introduction to Tax Equity Structures ? Part I
Bill Fisher Tom Stevens
Deloitte Tax LLP
September 29, 2014
Introduction to Tax Equity Structures
Part I ? ? Summary of Qualifying Resources and Facilities ? Partnership Flip Structure ? Sale Leaseback Structure Part II ? ? Inverted Lease Structure ? Power Prepayment Structure ? Summary of Major Tax Issues ? Yieldco and Other Financing Trends
2
Copyright ? 2014 Deloitte Development LLC. All rights reserved.
Summary of Qualifying Resources and Facilities
Energy property Solar
ITC rate *
30% 10%
Placed-in-service date
Before 1/1/2017
Treasury grant **
30%
Notes
Fuel cell
30%
Before 1/1/2017
30%
Stationary microturbine
Geothermal heat pump
10% 10%
Before 1/1/2017 Before 1/1/2017
10% 10%
Small wind
30%
Before 1/1/2017
30%
Combined heat/power
10%
Before 1/1/2017
10%
Geothermal
10%
10%
Alternatively , PTC is available.
* Available for public utility property in tax years ending after 2/13/2008.
** For Treasury grant eligibility, construction must have begun by the end of 2011 and an initial application must have
3 been filed by 10/1/2012. Does not reflect reduction due to sequestration.
Copyright ? 2014 Deloitte Development LLC. All rights reserved.
Summary of Qualifying Resources and Facilities
Qualified Resources/ Facilities
Credit Amount for 2014
Wind
2.3 cents/kwh* (10 years)
Geothermal (new facilities)
2.3 cents/kwh* (10 years)
Closed-loop biomass
2.3 cents/kwh* (10 years)
Open-loop biomass
1.1 cent/kwh* (10 years)
Municipal solid waste (landfill gas, trash)
1.1 cent/kwh* (10 years)
Hydropower, Marine and hydrokinetic renewables (including small irrigation power)
1.1 cents/kwh* (10 years)
4 * Adjusts for inflation. 2014 rate.
Begun Construction Date
Before 1/1/2014
30% ITC in lieu of PTC
If elected
Before 1/1/2014
If elected
Before 1/1/2014
If elected
Before 1/1/2014
If elected
Before 1/1/2014
If elected
Before 1/1/2014
If elected
Copyright ? 2014 Deloitte Development LLC. All rights reserved.
Tax Incentives are Integral to Project Economics
? What if I can't monetize the incentives currently?
? 1-year carryback / 20-year carryover period
? Multiple monetization structures are utilized ? Partnership flip ? Sale-leaseback ? Inverted lease ? Power prepayment
5
Copyright ? 2014 Deloitte Development LLC. All rights reserved.
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