Green Summit

Our expertise · Specialty Tax Incentives

Section 48E Clean Electricity Investment Credit Support

Under 48E, the dates decide the credit before the equipment does.

Section 48E is technology-neutral: a generating facility qualifies because its greenhouse gas emissions rate is not greater than zero, not because of what it is called, and energy storage technology qualifies on its own. Federal legislation enacted in July 2025 (Public Law 119-21) made timing decisive. A wind or solar facility whose construction began after July 4, 2026 now has to be placed in service by December 31, 2027, while storage keeps a longer runway. Green Summit supports owners, developers and their tax advisors with the construction-start evidence, technical description, cost records and placed-in-service documentation a 48E claim depends on.

Who this is for

Owners, developers and public or Tribal entities building solar, storage or other zero-emission generation, and the accounting firms advising them on the credit.

Accounting & Advisory FirmsAffordable Housing & Housing AuthoritiesBuilding Owners, Investors & OperatorsGovernment & Public InstitutionsManufacturers & Technology CompaniesReal Estate DevelopersTribal Nations & Tribal Organizations

What we do

  • Screen the dates first. We document when physical work of a significant nature began, whether construction has continued and when the facility was or will be placed in service, because those dates decide which rules apply and whether a wind or solar project still qualifies.
  • Describe the facility. We define each facility and each storage system, their capacity in AC and DC terms and the interconnection property, so the claim rests on what was actually built.
  • Substantiate the cost basis. We connect contracts, invoices and installed scope to the facility, separating eligible property from ineligible costs, so your advisor can compute the qualified investment on evidence.
  • Organize sourcing evidence. We collect manufacturer and supplier documentation your advisors need for the domestic-content bonus and the prohibited-foreign-entity material assistance test.
  • Coordinate labor and ownership questions. We identify the prevailing wage and apprenticeship records your contractors must keep and the ownership facts your advisors must confirm, before construction rather than at filing.

Our process

  1. Screen the technology, the claimant and the dates. We establish what is being built, who will own it, when construction began and when it will be placed in service, and we tell you early if a deadline puts the credit at risk.
  2. Confirm what your tax team needs. We agree the facility boundaries, the cost categories and the bonus-credit evidence your advisors will test before the engineering work begins.
  3. Deliver the engineering record. We hand off the construction-start, technical, cost and placed-in-service documentation with the open items listed, and we stay available to your advisors after filing.

What you receive

A 48E technical support package: a dated construction and placed-in-service record, a facility and storage description, a cost-basis schedule tied to the installed scope, and the sourcing and labor documentation checklist for each bonus or restriction that applies. Your tax advisor determines the credit rate, any bonus and the return position; none of them is guaranteed, and we never present them as if they were.

Benefits

  • Early warning when a construction-start or placed-in-service date puts the credit at risk, while there is still time to act.
  • A cost basis your advisor can defend item by item, not a percentage applied to a contract price.
  • One record that serves your tax advisor, a credit buyer or the elective-pay registration, and an examiner.

Why Green Summit

Green Summit is a trusted consulting partner delivering end-to-end compliance solutions in specialty tax credits and incentives, building performance and advisory services. We are engineers who also inspect and verify solar systems in the field, so the facility your advisor claims is the facility we have documented, from construction start to placed in service.

Founded in 2014 as a licensed engineering firm, we build every record to be audit-ready from day one, and our findings are engineered substantiation, not estimates.

Frequently asked questions

What is the Section 48E credit?

Section 48E is the federal clean electricity investment credit for zero-emission generating facilities and energy storage technology placed in service after 2024. The credit is a percentage of the qualified investment: 30% when the prevailing wage and apprenticeship requirements are met or the facility is under one megawatt, 6% otherwise, with possible bonus amounts for domestic content, energy communities and certain low-income projects. Your tax advisor determines the credit; our work supplies the engineering and cost evidence behind it.

Can a new solar or wind project still qualify?

Possibly, but the dates are now decisive. If construction began on or before July 4, 2026, the December 31, 2027 placed-in-service deadline does not apply, though the project must still show continuous construction. If construction began later, the facility must be placed in service by December 31, 2027. We document both dates before you rely on the credit.

Is battery storage treated the same way as solar?

No. Energy storage technology is not subject to the wind and solar deadline and keeps the full credit for construction beginning through 2033. It faces a higher foreign-entity material assistance threshold than generating facilities, so the supplier documentation matters even more.

Can a nonprofit, public agency or Tribe use 48E?

Yes. Tax-exempt organizations, state and local governments and Tribal governments can elect direct payment of the credit instead of using it against tax, and taxable owners can transfer it for cash. Both routes require registration before filing; our [Elective Pay / Direct Pay Support](/expertise/elective-pay-direct-pay/) page explains the process.

How is 48E different from the former Section 48 credit?

Section 48E replaced Section 48 for facilities placed in service after 2024 and qualifies them by emissions rate rather than by a list of technologies. Projects that began construction before 2025 may still fall under the former Section 48 rules; the date screening tells you which provision applies, and our [Energy Investment Tax-Credit Support](/expertise/energy-investment-tax-credit/) page covers both.

What records support a 48E claim?

Contracts, invoices and schedules of values, construction-start evidence, interconnection documents, equipment specifications, manufacturer certifications and placed-in-service records. Prevailing wage and apprenticeship records are kept by your contractors; we identify what they must keep. Please share them through the secure process we set up with you, not the website form.

Let's check the dates before you count on the credit.

Tell us the technology, the site, who will own it and when construction started or is expected to start.

Related solutions

Program and technical references

Internal Revenue Code Section 48E, as amended by Public Law 119-21 (July 4, 2025) - reference

IRS Notice 2025-42, Beginning of Construction for Wind and Solar Facilities - reference

Program information reviewed October 9, 2026. Current applicability, qualifications and program terms are confirmed for each engagement.

Or call 321-273-2200 · inquiry@greensummit.com

Please do not include tax returns, household income records, payroll or other sensitive documents in this initial inquiry.