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A CPA's Guide to §48E Tax Credit Transfers: Screening, Review and Reporting
If a client has C corporation tax or meaningful passive income, a §48E purchase may be worth evaluating. This guide sets out a CPA-side process: who to screen, what to review, how the credit is reported, and what to monitor for five years. Veritas supplies the diligence package; you keep the advice and the client relationship.
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1. Screen the client
- C corporation: federal tax after existing credits, §38(c) capacity, NOLs, bonus depreciation (§38(c)).
- Individual or trust: net passive income and the tax attributable to it (passive guide; qualifying clients).
- S corporation or partnership: see entity-level rules.
- Timing: tax year, estimated payments, extension plans (year-end guide).
2. Review the §48E-specific items
- Registration number, placed-in-service date, qualified basis and credit rate.
- Prevailing wage and apprenticeship support; energy community and domestic content support for any bonus (bonus guide).
- For wind and solar, beginning-of-construction and placed-in-service evidence (deadline guide).
- Foreign-entity (MACR) support for projects that began construction after 2025 (FEOC).
- Seller strength, indemnity, insurance (full checklist).
3. Engage and paper the deal
Add the purchase to the engagement scope and get client consent (engagement letter points). Review the agreement with the transfer agreement checklist and the §48E key terms. Disclose any relationship with Veritas to your client as your professional rules require.
4. Report
The buyer reports the credit on Form 3800 with the transfer election statement (guide). Passive-activity credits also use Form 8582-CR. The seller claims the credit on Form 3468 and makes the election; ask for a copy of the election statement.
5. Monitor for five years
Calendar the recapture years. Confirm the seller's covenant to notify you of a sale, foreclosure, casualty or change in use, and keep payroll, insurance and ownership documents. Recapture steps down 20 points per year (§50; Crux). Details: recapture risk and insurance.
See also our general transferable credit diligence guide, the §48E buyer guide and the CPA program overview.
Frequently asked questions
What should a CPA review before a client buys a §48E credit?
The registration number and transfer election, placed-in-service date and basis, prevailing wage and bonus support, foreign-entity (MACR) support for post-2025 construction starts, wind and solar deadline evidence, the seller's indemnity and insurance, and the client's own capacity.
How does the client report a purchased credit?
On Form 3800 with the transfer election statement. Individuals with passive activity credits also use Form 8582-CR. Confirm the tax year with the seller's placed-in-service date.
What should I monitor after closing?
Anything that could cause recapture or disallowance during the five-year period: a project sale or foreclosure, destruction, change in use, wage-rule failures, and the seller's notices under the agreement.
Does Veritas give tax advice?
No. Veritas provides educational information and transaction support. The CPA gives the advice, and the client decides.
- 26 U.S.C. §48E, Clean electricity investment credit (Cornell LII)
- 26 U.S.C. §6418, Transfer of certain credits (Cornell LII)
- IRS: Instructions for Form 3800, General Business Credit
- IRS: About Form 8582-CR, Passive Activity Credit Limitations
- 26 U.S.C. §50, Other special rules, including recapture (Cornell LII)
- 26 CFR §1.6418-5, Special rules (recapture and notification)
- Crux: What is recapture risk in tax credit transactions? (Aug. 26, 2026), third-party market data
- IRS: Elective pay and transferability FAQs, Transferability (Q4-Q15)