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VOL. IX · NO. 3 · JUL 2026

Energy Credits for Closely-Held Real Estate: A Sober Reading

Cutting through the hype on §179D, §45L, and the new transferability regime under IRA.

Sara Gonzalez, CPA

Founder & Managing Partner

PublishedJune 15, 2023

EffectiveTax Year 2023 onward

Reading9 min

The Inflation Reduction Act of 2022 vastly expanded federal energy tax incentives. ⁷ The One Big Beautiful Bill Act in 2025 sharply narrowed them. ⁵ For closely-held real estate owners and developers, the window to capture the most generous credits is closing, but for projects beginning construction by mid-2026, the after-fee economics remain compelling.

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In this essay

01 §179D. Energy Efficient Commercial Buildings Deduction 02 §45L. New Energy Efficient Home Credit 03 §6418. Transferability 04 Prevailing wage and apprenticeship 05 Bonus credit adders 06 Promoter due diligence 07 After-fee economics

Citations ¶ 7

IRC §179D (Energy Efficient Commercial Buildings Deduction)

Deduction statute with prevailing-wage/apprenticeship bonus tiers.

www.law.cornell.edu/uscode/text/26/179D ↗

IRC §45L (New Energy Efficient Home Credit)

$2,500/$5,000 per dwelling unit credit.

www.law.cornell.edu/uscode/text/26/45L ↗

IRC §6418 (transferability)

Cash-sale transferability of eligible IRA energy credits.

www.law.cornell.edu/uscode/text/26/6418 ↗

Rev. Proc. 2025-32

2026 §179D inflation adjustments.

www.irs.gov/pub/irs-drop/rp-25-32.pdf ↗

P.L. 119-21 §70507

OBBBA termination of §179D and §45L for projects beginning construction after June 30, 2026.

www.congress.gov/bill/119th-congress/house-b… ↗

CRS Report IF12596

Tax credit transferability market pricing analysis.

www.congress.gov/product/pdf/IF/IF12596 ↗

Inflation Reduction Act §13301 (P.L. 117-169)

IRA expansion of §179D and §45L base provisions.

www.congress.gov/bill/117th-congress/house-b… ↗

Cite this essay

Sara Gonzalez, Energy Credits for Closely-Held Real Estate: A Sober Reading, KGOB J. (Jun. 15, 2023).

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