Maximizing ITC Value Through Third-Party Ownership Structures
Monday, November 9, 2026 (2:00 PM - 3:00 PM) (EST)
Description
Third-party ownership can help ESCOs and their customers incorporate ITC-eligible technologies into ESPC projects when tax appetite, elective-pay timing, or capital constraints affect project economics. This educational session will compare partnership flip, lease pass-through, service-agreement, energy-as-a-service, and hybrid structures and explain how ownership, EPC terms, eligible basis, credit monetization, and compliance responsibilities must align.
Presenters:
Josh Howes, CEO, Walker Blue and Charlie Lord, Co-founder & Principal, Renew Energy Partners
Learning Objectives:
- Identify when third-party ownership may improve the economics and deliverability of an ESPC project compared with customer ownership, elective pay, direct use of the credit, or credit transfer.
- Compare partnership flip, lease pass-through, service-agreement, energy-as-a-service, and hybrid structures and explain how each allocates ownership, tax benefits, performance obligations, and risk.
- Evaluate how ITC eligible basis, cost allocation, depreciation, prevailing wage and apprenticeship, domestic content, energy-community eligibility, and foreign-entity restrictions affect projected credit value.
- Recognize common misalignments among EPC contracts, financing documents, service agreements, and tax-credit strategies that can delay closing or impair credit defensibility.
- Apply a development-to-filing framework that assigns stakeholder responsibilities and sequences diligence, construction documentation, placed-in-service evidence, pre-filing registration, and tax filing.
NAESCO has submitted this webinar to the AIA for 1 CEU approval.
NOTE: Beginning in 2023, all NAESCO webinars will be offered to all attendees at no cost. Recordings and slides will be available to members only, after the webinar.
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