Tax Equity & Hybrid Financial Modeling

Course Content

Build a Tax Equity financial model using a US renewable energy project as a case study.

This is an intensive course providing an overview of the tax equity structures commonly used in U.S. renewable energy investments, with a focus on the development of a financial model.

This is an advanced course and we strongly recommend completing our Renewable Energy Project Finance Modeling first. The Tax Equity course assumes knowledge of  (1) the initial grounding in best practice modeling techniques and (2) some of the tax concepts introduced in the Renewable Energy Project Finance Modeling course (“REPFM”). The Tax Equity course goes deep into tax capital accounts, deficit restoration obligations, stop loss allocations, and HLBV accounting. None of which  is contained in REPFM

Tax Equity & Hybrid Modeling In-House

Course Price: Contact Us

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Tax Equity and Hybrid Modeling Live Streaming

Course Price: $3200

January 22, 2025
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Tax Equity and Hybrid Modeling Live Streaming

Course Price: $3200

November 6, 2024
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Tax Equity and Hybrid Modeling Live Streaming

Course Price: $3200

January 22, 2025
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Live Streaming
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Tax Equity and Hybrid Modeling Online

Course Price: $900

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SECTION OVERVIEW

PRE-REQUISITES

 

 

 

 

 

 

  • This course presumes prior knowledge of advanced Excel functions, best practice financial modeling techniques and concepts such as debt sizing, debt sculpting, and optimizing a model to a required PPA price.
  • It is recommended to take the Pivotal180 Renewable Energy Project Finance Modeling Course before enrolling in this course

PRE-COURSE

 

 

  • Excel functions, formulas and shortcuts
  • Best practice modeling concepts
  • Data validation and named ranges
  • Tax equity model familiarization

PROJECT BENEFITS FROM DEPRECIATION, TAX CREDITS, AND CASH

 

 

 

 

  • Model familiarization and SPV calculations
  • Book versus tax depreciation
  • Taxable income (Earnings Before Tax)
  • Efficient versus inefficient (self-sheltering) taxpayers and NOLs
  • US tax credits – PTC, ITC, 45Q
  • Project level benefits of depreciation and tax
  • Introduction to the Inflation Reduction Act (IRA)

INTRODUCTION TO TAX EQUITY AND BACK LEVERAGE CONCEPTS

 

 

 

 

 

 

  • Review of US renewable energy incentives and project benefits
  • Introduction to tax equity
  • Tax equity rules, structures and terms
  • Partnership disproportionate allocations and flips
  • Tax equity risk and returns
  • Introduction to back leverage
  • Structure and terms of key tax equity contracts
  • Accounting considerations: GAAP and HLBV
  • Introduction to the Inflation Reduction Act (IRA)

INITIAL TAX EQUITY MODEL

 

 

 

 

 

  • Partnership sharing of benefits
  • Modeling disproportionate partnership allocations
  • Sizing tax equity investments
  • Back leverage structure
  • Back leverage debt sizing and repayments
  • Construction funding and tax equity bridge loans
  • Sponsor equity benefits, investment and returns

INSIDE BASIS

 

 

 

 

  • Introduction to tax capital accounts
  • Inside basis / s704(b) capital accounts
  • Stop loss reallocations
  • Deficit restoration obligations (DRO)
  • Determining who gets what out of the partnership
  • Impact of reallocations on tax equity investment sizing

OUTSIDE BASIS

 

 

 

 

 

 

  • Outside (tax) basis capital accounts
  • 704(d) suspended losses
  • Determining when losses can be utilized
  • Outside basis impact on taxable income and losses
  • s731(a) gains
  • s754 step-ups
  • s734(b) depreciation

 

CAPITAL ACCOUNTS, TAX EQUITY SIZING AND FMV

 

 

 

 

  • Review of tax capital account movements
  • DRO special income allocations
  • Impact of capital account reallocations and adjustments
  • Sizing tax equity investments after capital accounts
  • Circularity of tax equity sizing calculations
  • Fair Market Value (FMV) and step-ups

TAX EQUITY SIZING REVIEW

 

 

  • What matters most in tax equity transactions
  • Calendar dated flips (CDF)
  • Sponsor buyout options
  • Tax impact of buyouts

INFLATION REDUCTION ACT

 

 

 

 

  • Key changes under the IRA
  • Tax credit transferability
  • Direct credit transfers without tax equity
  • Hybrid tax equity structures (‘tax equity light’)

 

  • Self-paced, online
    • Complete this course online at your own pace.
    • Learn more or register today online training
  • Live streaming
    • Join virtually with other professionals in a small group environment to complete this course.
    • Learn more about our live streaming training
    • See our course schedule for upcoming course date
  • In Person
    • Join at a venue with other professionals in a small group environment to complete this course.
    • Learn more about our in-person training
    • See our course schedule for upcoming course date
  • Inhouse
    • This course can be customized to address the unique challenges that your team or organization face.
    • It can delivered via live streaming or in-person
    • Learn more about our customized training

This course will benefit the following people:

  • This course is best suited to people with experience in the sector, however those who have completed our Renewable Energy Project Finance Modeling course with a keen interest in tax equity are encouraged to join the tax equity course
  • Foreign investors looking to understand the US market
  • Analysts, associates, vice presidents and banks, funds, investors, developers and operating entities needing to understand the complexity of tax equity
  • CFOs or other finance team members of operating entities who have the misfortune of taking over a deal tax equity model

Why trust Pivotal180 with your professional development?

  • Pivotal180 is focused exclusively on teaching. Institutional and human capacity building is not a side business.
  • Senior practitioners with real experience lead Pivotal180 training courses
  • Our understanding is from practical transactional experience, not from reading about it or hearing about it from senior people on our team
  • We have trained top advisors, developers, lenders, and funds across the world.
  • We tailor our courses more than anyone else in the market, to meet your needs
  • Our blended solution of instructor led and online training includes 12 months of access to our online courses

Contact us for on-site or on-campus pricing and options.

The cost of the online course will be credited to you if you join a public or live streaming session within 12 months of purchase.

Discounts provided off the full course prices.

  • Students and non-profits are eligible for a discount of up to 50% (no other discounts may be added to this).
  • Online course price for students and non-profits is $450.
  • Student are not eligible, to renew their subscription and the license will expire after 12 months
  • Other discounts
    • Group booking of 3 or more people – 15%  Price per person for online group bookings is $765.
    • Early bird (interactive online sessions only ) if book 8 weeks before the course – 10%.

Cancellation Policy for Public Courses

  • 4 weeks before the course: Full Refund*
  • 1-4 weeks before the course: 50% Refund
  • <1 week before the course: No Refund

*Refund is less any merchant fees incurred on payment

  • 12 months access to our online material, including concept videos with transcriptions, lecture slides, downloadable spreadsheet examples.
  • A complete step-by-step model walk-through using an annual model, and access to discussion forums for ongoing questions.
  • A downloadable quarterly Tax Equity model
  • Subscription can be extended annually post the first 12 months for $100 per annum.
  • Lunch, tea & coffee at the venue (public session participants only).
  • Course completion certificate.
  • Access to Pivotal180 Communities

  • It is strongly recommended you have completed the Renewable Energy Project Finance Modeling Course (either as a public session or online) prior to taking this course. If you haven’t completed this recommended course, please speak with us to determine if the course is appropriate for you.
  • Knowledge of project finance pass-through entities, generation and operations of renewables projects, and tax calculations recommended (covered in recommended course above)
  • Best practice modeling skills
  • Advanced knowledge of, and access to Excel
  • Computer/Laptop (two monitors is preferrable)
  • Power Cord

Course Previews

US PTC tax credit

Tax equity s704b capital account

Tax Equity Model Familiarization