A specialty practice that does one thing: Section 6417 direct pay filings for tax-exempt organizations, from IRS registration through the refund. Engineering-based eligible basis, defensible returns, senior-led throughout.
The Inflation Reduction Act introduced Section 6417, allowing tax-exempt entities to receive direct payments from the IRS for clean energy tax credits, credits they previously couldn't use because they don't have federal tax liability.
GreenFile Advisory focuses exclusively on the filing and compliance side of direct pay: eligibility, IRS registration, the Form 990-T election, and refund monitoring. We do not sell panels, financing, or a credit percentage. We prepare the return that has to hold up.
Credits paid directly to your organization, no tax liability needed
Elections made on Form 990-T with proper schedules and registration
IRS Energy Credits Online portal registration required before claiming
The Investment Tax Credit starts at 30% of eligible project costs for qualifying projects. Bonus credits can stack on top of the baseline, and every one of them is payable in cash through a direct pay election.
Illustrative maximum. The 10% adders assume the project qualifies for the full 30% base rate (under 1 MW or prevailing wage and apprenticeship compliant); adders drop to 2% at the 6% base rate. Actual results depend on project size, location, sourcing, and program allocations.
Ten percentage points for projects in a qualifying energy community: a brownfield site, a census tract with retired coal infrastructure, or a statistical area that meets both a fossil fuel employment or tax revenue test and an unemployment rate at or above the national average.
Ten percentage points for projects using US-made steel, iron, and manufactured components. The manufactured products threshold is 40% for construction started by June 16, 2025, then 45% through year-end 2025, 50% in 2026, and 55% after. Supplier certifications carry the claim.
A capacity-limited allocation program for projects under 5 MW located in low-income communities or on Indian land (10%), or serving qualified low-income residential or economic benefit projects (20%). The 2026 application cycle closed August 7, 2026. We can advise on timing for the 2027 cycle.
Under the 2025 tax law, solar and wind projects that began construction by July 4, 2026 keep the standard multi-year window to be placed in service. Projects starting construction after that date must be placed in service by December 31, 2027 to qualify. If your project is in motion, the filing calendar deserves attention now, not at tax time.
Move the slider, toggle the bonus positions that might apply, and see the cash figure. Then let us confirm the real one.
Illustrative. Assumes the full 30% base rate (under 1 MW or prevailing wage and apprenticeship compliant); adders drop to 2% at the 6% base rate. Low-income bonuses are capacity-limited allocations. Actual results depend on project size, location, sourcing, and program allocations.
We prepare and submit the pre-filing registration on the IRS Energy Credits Online portal and obtain the registration number for each eligible property before the return is filed.
We prepare and file your Form 990-T with the required elections and schedules to claim your direct pay credits accurately and on time.
We build the substantiation file the return relies on, including bonus credit and sourcing documentation, and maintain it through the five-year recapture period.
We review your organization’s structure and clean energy investments to confirm Section 6417 eligibility and identify which credits apply to your situation.
We handle your pre-filing registration on the IRS Energy Credits Online portal, obtaining the required registration numbers for each eligible property.
We prepare your Form 990-T with proper elections and credit schedules, ensuring every line item is accurate and fully supported.
We e-file the return and, with Form 8821 authorization on file, monitor the IRS transcript from acceptance until the deposit lands. Any IRS notice comes to us first.
The beginning-of-construction date locks in key eligibility rules. Contracts and dated records matter from day one.
The credit is claimed for the tax year the project is placed in service.
The IRS recommends starting at least 120 days before your return is due.
Filed with Form 3468 and Form 3800 attached, along with the registration numbers.
The elected credit is treated as an overpayment and refunded by direct deposit or check. The IRS targets payment within about 45 days of the return due date; we track the transcript until it lands.
Most published guidance assumes a calendar year. School districts and municipalities on a June 30 year end run the opposite calendar. Register at least 120 days before the due date you are filing against.
| Fiscal year ends | Original 990-T due | Extended due (Form 8868) | Register on ECO by |
|---|---|---|---|
| December 31, 2025 | May 15, 2026 | November 16, 2026 (the 15th is a Sunday) | About July 19, 2026, if extended |
| June 30, 2026 | November 16, 2026 | May 17, 2027 (the 15th is a Saturday) | About January 17, 2027, if extended |
| December 31, 2026 | May 17, 2027 | November 15, 2027 | About July 18, 2027, if extended |
Yes. That is the entire point of Section 6417. Eligible tax-exempt and governmental entities receive a payment equal to the full value of the credit, including any bonus credits, after filing the election on a timely return.
No. Direct pay itself was not changed. The law did accelerate deadlines for solar and wind, and new foreign-sourcing rules apply to projects beginning construction in 2026 and later, which makes supplier documentation more important than before.
Not at all. Many organizations file a 990-T for the first time solely to make the direct pay election. Filing one does not create unrelated business income tax by itself.
It can. Certain grants and forgivable loans interact with the credit calculation. This is one of the areas we review during eligibility confirmation so there are no surprises after filing.
The IRS states a target of about 45 days from the return due date, and in practice timing varies with the filing season and whether the return needs any follow-up. One thing that can reduce the credit is tax-exempt bond financing, which trims it by up to 15%; we model that up front so the number you budget against is the number that arrives. With a Form 8821 authorization on file we monitor your IRS transcript from acceptance until the deposit lands, so you are never guessing where the money is.
GreenFile Advisory is the Section 6417 direct pay practice of Dedux Tax Consulting and Advisory. The practice is led by Andrew Nlemadim, MBA, EA, Practice Lead, who came to tax from energy efficiency and engineering and has worked in cost segregation and specialty tax incentives for over a decade. The practice has focused on Inflation Reduction Act incentives since they took effect in 2022, and takes engagements nationwide.
That background is why the practice leads with eligible basis, documentation, and substantiation rather than with a credit percentage. What a project actually cost, and which parts of it qualify, is an engineering question before it is a filing question. Getting it wrong is what turns a clean credit into an audit exposure.
Every engagement is led by the practice lead from scoping through refund. The person who scopes the work is the person who signs the return, and that person is an Enrolled Agent.
A scoping review confirms eligibility, the filing calendar, and what the credit is worth net of adjustments. Then a written proposal, then an engagement letter. Work begins when it is signed.
Request a Scoping Review