§48E — Investment tax credit for zero-emissions generation
30% ITC on qualified investment, technology-neutral. Stacks with domestic content (+10%), energy community (+10%), and low-income community (+10–20%) bonuses for up to 70% effective ITC.
The trade
§48E is the ITC counterpart to §45Y — pick one per project. Tokenization of an ITC is mechanically different from a PTC: the credit is earned at placed-in-service date, not per-MWh, so XCT-48E is minted as a single tranche at PIS rather than as a continuous stream.
OTC Desk
liveBilateral, wire-settled (or stablecoin at buyer's election). No tokenization required. Every IRA credit transaction we've closed to date has happened this way — the proven path.
About the OTC DeskOn-chain marketplace
testnetCredit tokenized as XCT at production. Marketplace bid book; atomic swap for MXD; transfer election booked on-chain. Continuous price discovery, faster settlement.
About §6418 transferabilityMechanics
| Bonus | Rate | Cumulative max |
|---|---|---|
| Base (PWA-satisfied) | 30% | 30% |
| Domestic content | +10% | 40% |
| Energy community | +10% | 50% |
| Low-income community | +10–20% | 70% |
- Earn: at placed-in-service
- Mint: single tranche of XCT-48E at PIS
- Recapture: 5-year window per §50
Status
Planned. Awaiting Treasury final guidance on Direct Pay & §6418 interaction for project-finance structures.
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