How a C Corporation Buys §48E Credits: Capacity, Timing and Accounting

A C corporation with federal income tax can buy §48E credits under §6418 and apply them against regular tax, up to the general business credit limit. §48E is where most corporate buyers look first because the credit is determined once, for a single tax year, and the supply spans solar, storage and other generation. This page covers the steps and the traps.

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1. Size your capacity

Purchased credits are general business credits. Under §38(c) the amount you can use in a year is generally your net income tax less the greater of the tentative minimum tax or 25% of net regular tax above $25,000, which is about 75% of net regular tax plus $6,250 when the minimum tax is zero. Your own credits, NOL use and bonus depreciation all change the answer. See the §38(c) limit, capacity after bonus depreciation, and NOLs and the 80% limit. Unused general business credit can carry forward (carryforward rules).

2. Choose the tax year and timing

A §48E credit is claimed for the year the project is placed in service, so confirm which tax year you will report it in. The IRS lets buyers consider purchased or intended credits when working out estimated payments; see estimated payments, the December 15 payment, and fiscal-year timing. Cenet Capital (third-party) notes the fourth quarter is the most crowded time to shop.

3. Get §48E offers

Ask for indicative offers for credits claimed in your target year, with the seller identity, project type and credit support. Third-party pricing is in our pricing guide. Compare broker, marketplace and direct paths in this guide.

4. Diligence the credit

Use the §48E due diligence checklist. Corporate buyers usually also confirm foreign-entity status for the buyer itself and the project (FEOC guide).

5. Document, pay and report

Sign a transfer agreement, pay cash, and report the credit on Form 3800 with the transfer election statement (reporting guide). Talk to your auditors early about ASC 740 accounting and how to present the five-year recapture exposure.

Why §48E may fit a corporate buyer

• You can buy one block for one year instead of a multi-year strip of production credits.
• The ITC deal form is widely used, and indemnity and insurance are standard (Crux; Cenet).
• Supply is broad (see the comparison).

Where it may not fit

• You cannot absorb recapture exposure for five years.
• Your capacity is smaller than the minimum block a seller will sell.
• You have no taxable income to offset, or your liability is mostly alternative minimum tax.

Step-by-step overview: how a C corporation buys credits and year-end 2026 planning. Our C corporation hub has the rest.

Educational information only, not tax, legal or investment advice, and no outcome is promised. Rules and figures were checked against the cited sources on October 29, 2026; they change, so confirm with your CPA and counsel before acting. Market figures are third-party data and are not Veritas quotes. See our disclaimer.