The Vendor is required to provide professional tax advisers with a strong record in successfully assisting local governments and other entities with the implementation of projects involving IRS energy tax credits and federal funds, including funds.
- Pre-procurement structuring and tax credit analysis
• Evaluation of applicable credit structure, including prevailing wage and apprenticeship requirements, domestic content eligibility, and potential energy community eligibility
• Development of high-level project scenarios comparing alternative project sizes and configurations and associated direct pay outcomes
• Assessment of whether the proposed project site may qualify as an energy community under current IRS guidance and identification of required supporting documentation
• Evaluation of timing and eligibility risks associated with energy community qualification over the project lifecycle, including risk of changes prior to placed-in-service
• Recommendations regarding whether to pursue energy community bonus credits and how such strategy should be reflected in the RFP and procurement approach
- Vendor compliance evaluation (finalist review)
• Evaluation of each finalist’s proposed system, equipment, and project configuration for compliance with eligibility requirements
• Assessment of each finalist’s ability to meet:
o Domestic content requirements
o Prevailing wage and apprenticeship requirements
o Documentation and substantiation requirements necessary for direct pay
• Identification of risks that could impact the client’s ability to claim or receive the tax credit, including risks of partial or full disallowance
- Ongoing compliance monitoring and advisory support
• Advising the client during:
o Procurement
o Construction
o Installation
o Commissioning (placed-in-service determination)
• Review of material project changes, including change orders or scope modifications, for potential impact on tax credit eligibility or value
• Guidance on documentation collection, verification, and retention necessary to support tax credit claims and audit defense
• Assistance in identifying and addressing compliance issues as they arise during project execution
- Direct pay filing and audit readiness support
• Advising on pre-filing registration requirements
• Supporting preparation for tax credit filing, including coordination with accountants or tax preparers
• Ensuring that all required documentation and substantiation materials are complete and audit-ready
• Providing guidance on audit risk and defensibility of the tax credit claim.
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