Is a solar tax-credit appraisal a valuation of the equipment or of the project company?
Usually of the project company or a partnership interest in it. The investment credit under Sections 48 and 48E is a percentage of the basis of energy property. When that basis comes from a purchase price, the appraisal has to support the fair market value of what was bought and allocate that price so goodwill stays out of credit-eligible basis.
What is the residual method, and why does it matter for ITC basis?
When a project-company purchase is treated as an applicable asset acquisition, Treas. Reg. 1.338-6 allocates the price through seven asset classes. Energy property is Class V. Contract rights such as power purchase agreements generally fall in Class VI. Class VII (goodwill and going concern) earns no credit. A valuation that supports a step-up has to value each class, not only the total.
Do Section 6418 credit buyers need a valuation?
A credit buyer reviews whether the seller's basis rests on construction cost or on a purchase price, and how that price was supported. An independent USPAP report that states the approaches and the allocation is the document that review starts from. Qualification and credit eligibility remain legal questions for counsel.
What documents do you need to start?
Construction contracts and cost reports, the purchase or membership-interest agreement, the operating or partnership agreement, offtake contracts, and the production and financial models. If a document does not exist yet, we say at scoping whether the valuation can proceed without it.