Investment Tax Credit · Tax Asset Utilization · Renewable Energy

A third path beyond
ITC transfer and tax equity.

Aeon Capital structures proprietary Tax Asset Utilization agreements that move tax liability without transferring credits — no recapture exposure, no bridge financing, no partnership complexity.

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$380M

2026 TAU Pipeline

40%

ITC Rate

350+

Projects Nationwide

2025

Fully Subscribed

The Market

Three ways to access the ITC.
One is different.

The market has given institutional investors two options for decades. Aeon Capital built a third.

Option 1

ITC Transfer
(§6418)

Purchase credits directly from the project
Requires bridge financing (90–120 days)
Recapture risk stays with buyer
Market price: 90–95¢ on the dollar
No equity stake or depreciation

Option 2

Tax Equity Flip
(Partnership)

Equity partner in project partnership
Receives ITC + MACRS depreciation
5-year recapture tail on the credit
BBA audit exposure for partnership
Complex §704(b) allocation mechanics

Aeon Capital

Option 3

Tax Asset
Utilization (TAU)

Acquire energy-backed NRGSC units at documented FMV
§162 deduction on transfer — ITC never touches you
Zero recapture exposure at investor level
No bridge financing required
No partnership, no BBA audit exposure
Quarles & Brady reviewed the mechanics

How It Works

Tax Asset Utilization

TAU moves tax liability through a documented contractual structure — not a credit transfer. The ITC stays in the project entity. The investor takes a §162 deduction on assets transferred at arm's length.

Income Relocation

The investor relocates qualifying income into the project SPV through a documented contractual arrangement. The SPV recognizes §61 income — a matched pair from day one.

NRGSC Acquisition

The investor acquires energy-backed NRGSC units at documented fair market value — supported by six arm's-length hotel transactions and an independent IntegriPoint appraisal at $250/unit.

§162 Deduction

The investor transfers units to the SPV and takes a §162 ordinary deduction on the FMV transferred. The ITC offsets the SPV's income tax — never the investor's. No recapture. No credit exposure.

Clean Exit

The program absorbs the units and builds additional systems. The investor has no ongoing asset, no partnership obligation, and no federal credit on their books.

Why TAU beats the alternatives

No recapture tail — liability stays inside the SPV
No bridge financing — structure closes without a lender
No partnership complexity or BBA audit exposure
§162 deduction is the oldest mechanism in the code
Matched §61 income pair — no circular cash flow
Six documented arm's-length transactions establish FMV
IntegriPoint independent appraisal at $250/unit
Quarles & Brady has reviewed the mechanics
2025 was fully subscribed — 2026 allocation now open

TAU stands on 40 years of tax equity precedent. If the partnership flip is defensible, TAU — with a stronger FMV foundation and zero recapture exposure — is categorically more defensible.

Advisory Network

Institutional expertise across
every dimension of the deal.

Aeon Capital operates with best-in-class advisors spanning tax law, valuation, energy finance, and accounting.

Tax & Energy Law

National law firm with one of the deepest energy tax benches in the country. Lead counsel on ITC qualification, transfer documentation, and TAU structure review.

Cost Segregation & ITC

Specialist tax advisory firm focused on ITC pre-filing registration, cost segregation, and investment tax credit qualification analysis for energy assets.

Valuation & Appraisal

Independent appraisal firm providing fair market value opinions on renewable energy systems and NRGSC program assets — establishing the defensible FMV basis underpinning every transaction.

Tax Credit Finance

Specialized tax credit investment platform providing capital markets access for transferable investment tax credits — connecting qualified energy projects with institutional buyers at scale.

Securus Advisors — Partner

CPA and tax strategist bringing Big-Four accounting expertise and Ivy League credentials to ITC program review, safe harbor analysis, and institutional investor due diligence.

ITC Pre-File Registration

Global tax services leader. Completed the inaugural ITC pre-file registration for the Aeon Capital portfolio — establishing the program's first-filed compliance record with the IRS Energy Credits Online portal.

A third path beyond
ITC transfer and tax equity.