Clean Energy Tax Credit Market Thrives Despite New Limits

Tax attorney Nicole Elliott was quoted in a Law360 article about the continued growth of the clean energy tax credit transfer market, even after the 2025 budget law imposed new limits on certain solar and wind incentives. The article explained that transferability under Internal Revenue Code Section 6418 has become a powerful financing tool allowing developers to sell credits directly to corporate taxpayers and access liquidity more efficiently than through traditional tax equity structures. Ms. Elliott noted the market's resilience amid rule changes and its expansion into areas such as advanced manufacturing, clean fuels, storage and nuclear.

"Transferability remains strong," she commented. "I think it has proven to be a very effective tool to turbo-boost these credits."

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