Guide · choosing a route
Sell the credit, keep it, or something else?
A §6418 sale is one of five ways to turn a clean-energy credit into value. Which one fits depends on your tax bill, your size and who you are. Here they are side by side, with the rule that catches people in each.
Verified · page reviewed 11 Oct 2026
The five routes at a glance
| Route | Who can use it | What you get | Cost or discount | The trap |
|---|---|---|---|---|
| Use it yourself | Anyone who owes enough federal income tax | The full credit against your tax, within the general business credit limits | None | Unused credit can be carried, but a carried credit can never be sold |
| Carry it back or forward | Anyone, for the part you cannot use this year | Back 3 years, forward 20, for these credits | Time: you wait for the tax bill to absorb it | Same: once carried, it cannot be transferred |
| Sell it (§6418) | Any eligible taxpayer, to an unrelated buyer | Cash, typically 80 to 96 cents per $1 | The discount, a broker fee and legal costs | Original return only, registration first, cash inside a set window |
| Tax equity | Projects large enough to attract an investor | An investor funds the project for most of its tax benefits | Complex; costs can exceed $1 million a deal | Few investors; built for large projects |
| IRS direct pay (§6417) | Tax-exempt and public bodies; any business for §45V, §45Q, §45X, for five years | A payment for the full credit | None beyond compliance | For businesses: no sale of that credit in those years |
Sources for each row are in the sections below.
Use it yourself
If you owe federal income tax, the credit reduces it dollar for dollar, within the limits on general business credits[1]. No discount, no buyer, no fees. The limits and, for individuals and some closely held companies, the passive activity rules decide how much you can use in a year; that is a question for your tax adviser.
Carry it back or forward
For these clean-energy credits, any amount you cannot use is carried back three years and forward twenty[1]. That preserves the value, but it waits on future tax bills.
The catch: only current-year credits can be sold. A carryforward or carryback cannot be transferred[2]. If you might want to sell, decide before you file the return for the year the credit arises: the election has to be made on that original return, and cannot be made for the first time on an amended one[3].
Sell it under §6418
You sell all or part of the credit to an unrelated buyer for cash; the buyer is then treated as the taxpayer for that credit, and the cash is not income to you[2]. Most credits sell for about 88 to 96 cents per dollar; small, uninsured deals for 80 to 89[4]. The steps are on how a transfer works, and the numbers on the prices page.
A sale moves only the credit. You keep the project. For §48, §48C and §48E property, its basis is still reduced as if you had claimed the credit yourself[5].
Tax equity
In a tax equity deal, such as a partnership flip, an investor co-owns the project and is allocated a share of its cash and most of its tax benefits[6]. These structures are complex to set up and manage, the combined legal, diligence and accounting costs can exceed $1 million for a single deal, and two major banks have provided more than half of tax equity in recent years[6]. For a large project it can still be the right answer, because the investor takes the tax benefits beyond the credit.
Tax equity is not standing still: Crux expects hybrid tax equity structures to account for about $28.8 billion in 2026[7].
IRS direct pay (§6417)
Direct pay treats the credit as a payment of tax, so the IRS pays out the full amount. It is open to[8]:
- tax-exempt organisations;
- states and their political subdivisions;
- the Tennessee Valley Authority;
- Indian tribal governments;
- Alaska Native Corporations;
- rural electric co-operatives.
Any other business can elect direct pay for only three credits: §45V clean hydrogen, §45Q carbon capture and §45X manufacturing. The election covers the first year and the four years after it, ending before 1 January 2033, and for all three no transfer election is allowed for that credit in the years it covers. A business can revoke the election for the later years, but cannot undo the revocation[8].
A short decision path
- Do you owe enough federal income tax to use the credit this year? If yes, compare using it with the after-cost price of a sale. Using it avoids the discount.
- Are you a tax-exempt or public body, or do you have a §45V, §45Q or §45X credit? Look at direct pay before a sale.
- Is the project large, with a sponsor that wants an investor partner? Tax equity, or a hybrid, may beat a straight sale.
- Otherwise, a §6418 sale turns the credit into cash this year. Check what a buyer will ask for with the Readiness Checker and what the credit may fetch with the Credit Value Estimator.
Sources
- 26 U.S.C. § 39 — Carryback and carryforward of unused credits
- 26 U.S.C. § 6418 — Transfer of certain credits
- 26 CFR § 1.6418-2 — Rules for making transfer elections
- Tax credit transfer market report: prices and volumes, Q4 2026 (4 Oct 2026)
- Instructions for Form 3800 (2025)
- Transferable tax credits comprehensive guide 2026
- 2026 mid-year market intelligence report: 5 takeaways for clean energy developers (20 Aug 2026)
- 26 U.S.C. § 6417 — Elective payment of applicable credits