All of a sudden you could buy these credits without having to invest in a project.
Banks only have so much tax-credit appetite, and the economy is not growing fast enough for their appetite to absorb all the new credits. It requires new companies coming in.
Pre-IRA there were maybe 50 or 60 companies involved in tax credits at high volume. Now the entire Fortune 500 is either actively participating or starting to.
They're phasing out, but it's a softball phaseout. The worst-case fears of an immediate repeal did not materialize.
The clean energy tax credit landscape is evolving, but remains highly investable.
Meeting the foreign-entity requirements is going to be one of the greatest challenges for the industry.
Direct pay is purely public, with no private partner to ensure that only the most viable and deserving projects clear the bar.
If the government wants to discourage you from doing something, they tax you. If they want to encourage you, they give you a tax credit.
Power demand is growing again, and it needs capital.
After fifteen flat years, American electricity demand is rising about two percent a year on data centers, manufacturing and electrification. The institutional capital financing that buildout has more than doubled since 2022, and a new channel, transferable tax credits, has brought a quarter of the Fortune 1000 into the market. Recent law changes and tariffs have changed the rules, but they haven't changed how much capital the buildout needs.
Sources: EIA Short-Term Energy Outlook and Annual Energy Outlook 2026 · Buying Power, drawing on Norton Rose Fulbright cost-of-capital panels and industry estimates
Ten years on the investor side.
Built an infrastructure investment platform from the ground up over a decade, and helped pioneer the transfer flip and the first tax equity investment in standalone battery storage. Board of Directors, Goodwill of Colorado. His first book, Buying Power, is forthcoming from Forbes Books.
About Bryen