Transferable tax credits, learned properly.
A ten-episode podcast and a question game built from the Reunion Transferable Tax Credit Handbook v4.2 (July 2026) and the Section 48 / 48E summary. Everything from why the market exists to what a dollar of credit costs and who eats the loss when the IRS disagrees.
🎮
Credit Desk — the game
~180 questions across 10 topics. Weak-topic weighting, revenge queue, Numbers Gauntlet, Boss Run.
⚡
Cram sheet
Every rate, threshold, date and dollar figure on one printable page.
The podcast
Two hosts, roughly 12–25 minutes each, about 2½ hours total. Delivered as MP3s — play them anywhere.
- 01
Why This Market ExistsTax equity's bottleneck · §6418 · cash treatment · the once-only rule · carryback/forward · mismatched tax years
- 02
Investment Tax Credits: §48 and §48E6% → 30% · the adder stack to 50% · §50 recapture and the foreclosure trap · basis risk · phase-downs
- 03
Production Tax Credits: §45 and §45YNo recapture · the §45Y metering path · rates and rounding · wind phaseout · repowering and 80/20
- 04
The Other Three: §45X, §45U, §45ZSubstantial transformation · integrated components · the nuclear gross-receipts clawback · clean fuel gates
- 05
Prevailing Wage & ApprenticeshipThe five-times multiplier · three apprenticeship tests · the 1 MW exemption · cures, penalties and waivers
- 06
The Bonus AddersEnergy community's three paths · domestic content and the elective safe harbor · the low-income lottery
- 07
Foreign Entity of ConcernSFE vs FIE · effective control · the material assistance cost ratio and its thresholds
- 08
Beginning of ConstructionPhysical work vs 5% · continuity · Notice 2025-42 — and the June 2026 decision vacating it
- 09
Pricing and CashflowWhat credits actually cost · the four pricing factors · zero-out-of-pocket structures
- 10
The DealRegistration · transfer election statements · reps, CPs, covenants · indemnity, guarantors, insurance · CAMT
A standing caveat, said in every episode: this material moves. PTC rates are re-published annually, FEOC guidance is still interim, and the beginning-of-construction rules for wind and utility-scale solar are in active litigation. Use this to build the map, then verify the current state before you rely on any specific number.
Study aid only — not tax advice.