Section 48E base credit at 30 percent. Domestic content and energy community adders up to 10 percent each. MACRS with 100 percent bonus depreciation. Construction must begin by July 4, 2026.
Commercial solar projects must begin construction by July 4, 2026 to qualify for the 30 percent Section 48E federal tax credit. After that date, the system must be placed in service by December 31, 2027.
Schedule Before the DeadlineThe Section 48E commercial solar Investment Tax Credit remains active at a 30 percent base rate for projects where construction begins by July 4, 2026. Two stacking adders -- domestic content and energy community -- can increase the effective credit to 50 percent. MACRS 5-year accelerated depreciation, restored 100 percent bonus depreciation, Direct Pay for tax-exempt entities, and C-PACE financing round out the commercial incentive stack. FEOC compliance is required for any project claiming the credit in 2026.
H.R. 1 (One Big Beautiful Bill Act, signed July 4, 2025) preserved and modified the commercial credit. The 40 percent non-FEOC component threshold applies in 2026 and escalates in subsequent years. ITC transferability allows owners to sell the credit to third parties. Direct Pay (Section 6417) allows qualifying tax-exempt entities to receive the credit as a cash payment. C-PACE financing is available in more than 32 states and requires no upfront capital. Verify all figures with your tax advisor.
H.R. 1 (the One Big Beautiful Bill Act) preserved and modified the commercial Section 48E credit. For systems where construction begins by July 4, 2026, the base rate is 30 percent with a placed-in-service window through December 31, 2030. We help commercial buyers understand every component of their incentive stack before construction begins.
Schedule a Commercial AssessmentSolar qualifies for 5-year MACRS accelerated depreciation. 100 percent bonus depreciation was restored January 19, 2025. Combined with the 48E credit, the year-one federal benefit is typically 45 to 55 percent of project cost. Your tax advisor should verify based on your specific tax position.
Tax-exempt entities use Direct Pay to receive the credit as cash. Taxable entities with insufficient liability can transfer the credit. Property owners in 32-plus states can use C-PACE for no-upfront-capital financing. Each path has specific requirements.
We assess your project against the 48E base rate, FEOC compliance threshold, and any applicable adders: domestic content, energy community, or low-income.
We work with your tax advisor to model the 5-year MACRS schedule and 100 percent bonus depreciation restoration, calculating the combined year-one federal benefit.
C-PACE, ITC transferability, and Direct Pay paths are evaluated based on your entity type and project structure.
System design begins construction before the July 4, 2026 deadline. Your tax advisor receives the documentation needed for credit filing.
The right structure depends on your entity type, tax position, and capital preference. The table below illustrates the main options; your specific project will require a detailed analysis. Figures are illustrative; verify with your tax and financial advisors.
| Category | Financing Path | Upfront Capital | 48E Credit Path | Best For | Key Considerations |
|---|---|---|---|---|---|
| Cash Purchase | Cash Purchase | Full project cost | Owner claims 48E + MACRS directly | Businesses with tax liability and capital | Highest long-term return; requires sufficient tax liability |
| C-PACE Financing | C-PACE | None | Owner claims 48E + MACRS; repays via property assessment | Property owners in 32+ PACE states | Repayment attaches to property; may transfer at sale |
| ITC Transfer / Sale | ITC Transfer | Project cost (offset by credit sale proceeds) | Owner sells 48E credit to third party at a discount | Owners with insufficient tax liability to use full credit | Tax attorney required; credit sold at 80-95 cents per dollar (market-rate) |
| Direct Pay (tax-exempt entities) | Direct Pay | Full project cost or financed | IRS pays credit value in cash to qualifying entity | Nonprofits, schools, municipalities | IRS pre-registration required; entity must own (not lease) the system |
| Power Purchase Agreement | PPA | None | Third-party developer claims 48E; may pass savings via lower PPA rate | Entities that cannot or prefer not to own the system | Entity does not own system; Direct Pay not available; savings depend on PPA terms |
See how the commercial incentive stack applies to your facility.
Our commercial ROI calculator models your Section 48E credit, MACRS depreciation, and payback period.
Contact us now to determine whether your project can meet the construction-start deadline. No obligation, no shared leads.