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Clean Energy Credit Review
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Advisor review

Give CPAs and tax attorneys the source letters and questions first.

Use this page to keep the diligence path clean: source letters, review questions, and advisor reliance before anyone treats an example as reliable.

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Advisor diligence

What your CPA or tax attorney should examine.

These are the diligence questions to work through with your own advisor: tax-year facts, final documents, source letters, and the limits on any example before reliance.

01

Credit section

Confirm the exact credit sections, ownership path, transfer or allocation treatment, and whether the claimed carryback period fits the credit.

02

Taxpayer fit

Review taxpayer type, entity structure, basis, at-risk rules, passive activity limitations, and material participation questions.

03

Documents

Request subscription documents, project documents, sponsor materials, allocation details, debt terms, opinions, and reporting forms.

04

Recapture

Confirm hold period, recapture triggers, exit terms, transfer restrictions, and what happens if the project or taxpayer facts change.

05

Funding

Understand the cash component, note or debt component, timing, payment obligation, and whether payout projections match documents.

06

Reliance

Document that the taxpayer is relying on their professional advisors and final documents, not public marketing copy.

Your intake is read by a person, not a bot. We screen for fit only. Any clean energy credit structure is confirmed against source materials and your own CPA or tax attorney before you rely on it.

Advisor sections

The three source letters to review separately.

These are the attorney and accounting letters to bring into CPA or tax-attorney review. Each one has a short parsed summary plus a separate PDF view, so the source material stays clean and easy to examine.

Attorney letter

Olson & Partners Law opinion letter

Olson & Partners Law | 28 pages | 771 KB PDF

This attorney opinion frames the legal questions around ownership, depreciation, federal solar tax credits, basis, passive activity treatment, and economic substance.

  • Reviews whether the system owner can be treated as the owner of the solar system for depreciation purposes, including economic-risk and title questions.
  • Addresses whether the structure supports claiming the federal solar tax credit for qualifying solar energy property.
  • Reviews the basis question, including whether purchase price and recourse seller-note treatment may be included in the system owner's basis analysis.
  • Discusses active versus passive treatment, material participation, and sham-transaction or economic-substance considerations.

Reliance note: Bring this to your own counsel as source material. It is not a tax or legal opinion from Clean Energy Credit Review.

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Accounting letter

WSRP Advisory tax opinion

WSRP Advisory | 4 pages | 866 KB PDF

This tax advisory letter explains the federal credit and depreciation mechanics that a CPA should test against the taxpayer's facts.

  • Summarizes Investment Tax Credit mechanics under IRC Section 48, including the base solar credit and potential domestic-content and energy-community bonus credits.
  • Covers accelerated depreciation, MACRS treatment, and the restored 100% bonus depreciation framework for qualifying property placed in service after January 19, 2025.
  • Explains the basis calculation concept, including the reduction tied to credits claimed and why state depreciation treatment may vary by state.
  • Discusses carryback and carryforward review, including the three-year carryback and twenty-two-year carryforward framework for many clean energy credits.

Reliance note: Bring this to your CPA as review content. Actual credit use depends on taxpayer liability, eligibility, limitations, timing, and advisor review.

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Accounting memo

Leo Berwick tax memorandum

Leo Berwick | 37 pages | 1.2 MB PDF

This transaction advisory memo focuses on transaction documentation, eligible basis support, placed-in-service evidence, and credit-adder support.

  • Reviews energy-property qualification, cost-basis methodology, placed-in-service documentation, begin-construction documentation, valuation support, and potential ITC adders.
  • Describes the transaction structure, including system-owner purchase, recourse seller note, title transfer at permission to operate, and power purchase agreement revenue mechanics.
  • Identifies eligible-cost documentation, installed equipment support, and why certain nonqualified costs should be excluded from ITC-eligible basis.
  • Discusses material participation, operational-risk assumptions, economic-substance considerations, and the documentation an underwriter or advisor would expect to evaluate.

Reliance note: Bring this to an advisor as transaction-review content only. It contains third-party reliance and distribution limits, so advisor review remains required before anyone relies on it.

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Start your review

Bring these questions to your advisor.

Start with a private fit screen. If a tax-year review may be worth pursuing, we prepare the source letters and diligence materials for your CPA or tax attorney before anyone relies on a structure.

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