SLB · Partnership Flip · Hybrid Transfer · Direct Pay — by Marciano
Project Inputs
Tax Equity Inputs
Direct Pay Structure
Depreciation
Bonus depreciation (100%)
Off = 5-yr MACRS (20/32/19.2/11.52/11.52/5.76%). On = 100% yr 1 on depreciable basis. Depreciable basis = cost − ½ ITC in all taxable structures.
Structures to Show
Sale-Leaseback
Partnership Flip
Hybrid + §6418 Transfer
Direct Pay (§6417)
Day-One Cash to Sponsor ($M)
Sponsor After-Tax IRR (20-yr PPA)
Sponsor 5-Yr MOIC (multiple on invested capital)
Sponsor Cash Flows — Year by Year ($M, after-tax)
Model assumptions: Project cost = hard cost basis; FMV = cost × 1.25 (for SLB gain calculation).
ITC basis = FMV for SLB, partnership cost for flip/hybrid, B% × cost for direct pay.
Depreciable basis = ITC basis − ½ ITC in all taxable structures. MACRS 5-yr half-year convention.
Bonus dep = 100% yr 1 on depreciable basis (available to SLB and direct pay A% sponsor always; flip/hybrid only if elected — market rarely elects per 1.46-3 capital account constraints).
TE funding modeled as upfront proceeds to sponsor at close. Flip TE pre-flip cash = 2% of TE investment/yr (preferred).
§6418 transfer proceeds paid at close, net of transfer price discount.
Direct pay: tax-exempt files §6417 post-commissioning; sponsor retains A% = (1−B%) with full ITC and bonus dep on A% basis.
No debt modeled. No gain on contribution (flip/hybrid). SLB gain = FMV − cost × sponsor tax rate, paid yr 1.
This is illustrative. Not a tax opinion.