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60-second version

• Transferability (IRC §6418) lets certain taxpayers sell eligible clean-energy and manufacturing tax credits to an unrelated buyer for cash.
• The buyer then claims the credit on its federal return (subject to the rules).
• Only a defined set of credits is transferable — and post-OBBBA (July 2025), that set is shrinking and date-dependent as several credits sunset.
• The seller must complete IRS pre-filing registration and obtain a registration number per credit property before the election is effective.
• Transfers to prohibited foreign entities are barred (FEOC restrictions added by OBBBA).
• If the transferred amount is later found overstated, the buyer can face tax consequences (excessive-transfer rules).

Pick your path

• How It Works — the process, cash rule, timing, and key constraints.
• Eligible Credits — every credit within §6418's scope, with sunset dates and status flags.
• Registration Filing — pre-filing registration, registration numbers, election timing.
• Risk & Compliance — due diligence, excessive transfer, recapture, FEOC.
• Glossary — definitions and FAQs.
• Updates — what changed in the law and on this site.

Choose your role

• Buying credits: start with Risk & Compliance, then open the credit page you're buying.
• Selling credits: start with Registration Filing, then open the credit page you're selling.
• Just learning: start with How It Works, then Eligible Credits.

Three non-negotiables

• Unrelated buyer: the transferee must be unrelated to the seller.
• Cash consideration: payment must be in cash.
• One transfer: the buyer generally cannot re-transfer the credit under §6418.

Full process: How It Works.

Why transferability matters

Many clean-energy credits are valuable but historically required the project owner to carry enough tax liability or use complex financing. §6418 created a more direct path: sell the credit to a company that can use it, for cash.

The difference

• Transferability (§6418): eligible taxpayers sell eligible credits to unrelated buyers for cash.
• Elective pay (§6417): certain entities treat the credit as a tax payment and may receive a refund.

Both require pre-filing registration and registration numbers. See Registration Filing.

If you're unsure

1. How It Works — understand the mechanics.
2. Registration Filing — understand what makes an election effective.
3. Risk & Compliance — understand buyer/seller risk and FEOC screening.

Credit index (each links to its page)

• §30C — alt-fuel refueling/EV charging. Terminated for property placed in service after June 30, 2026.
• §45 — renewable electricity PTC (legacy).
• §45Q — carbon oxide sequestration.
• §45U — zero-emission nuclear production.
• §45V — clean hydrogen. Accelerated termination — verify timing.
• §45X — advanced manufacturing. Wind components: no credit if sold after Dec 31, 2027.
• §45Y — clean electricity PTC. Wind/solar: begin construction after July 4, 2026 → in service by end of 2027.
• §45Z — clean fuel production. Extended through Dec 31, 2029.
• §48 — energy ITC (legacy).
• §48C — advanced energy project (allocation program).
• §48E — clean electricity ITC. Wind/solar: same deadline as §45Y.

Common confusion: §45 vs §45Y and §48 vs §48E are generally pre-2025 vs post-2024 frameworks. Open both pages and check placed-in-service timing.

Steps

1. Identify the credit and confirm it's within §6418's scope and still available for your timing.
2. Pre-filing registration: seller registers each credit property and obtains registration number(s).
3. Negotiate terms: price, indemnity, documentation, and timing.
4. FEOC screening: confirm the buyer isn't a prohibited foreign entity.
5. Cash consideration: payment must be structured as cash.
6. File and elect: seller makes the transfer election on its return with required registration number(s).
7. Buyer claims: buyer claims the transferred credit on its return.

The three buckets

• Eligibility risk: the project doesn't qualify for the claimed credit.
• Computation risk: the amount is wrong (production, basis, rate, or adder support).
• Filing/election risk: registration numbers or elections are missing or incorrect.

Plus, post-OBBBA: FEOC risk (transfer to a prohibited foreign entity, or the credit itself is FEOC-tainted). See Risk & Compliance.