Clean Flash Points: Tax Equity Checks, 5% Rule Returns, GameChange Fireside

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Clean Flash Points: Tax Equity Checks, 5% Rule Returns, GameChange Fireside

USA | Clean Energy EquityJuneResearch9, 2026

Clean Flash Points: Tax Equity Checks, 5% Rule Remain confident in a modest acceleration

in solar in near-term. Still see 'peaking out'Returns, GameChange Fireside of total solar build by ~2028. See challenged

Updated on recent discussions with the industry stakeholders on tax equity. economics in Texas as still driving some risk

of deceleration. Activity by big tech remains

Verdict: more friction vs structural; Court reinstates 5% safe harbor rule for the single biggest point to watch, but with

wind/solar; Conversation with GameChange: Expect market share growth, with elevated offtake pricing, we see solar as still

margins and ASPs stabilizing supply constrained.

Tax Equity Capital Markets | Friction, Not Freeze. Recent discussions about TE suggest a

disconnect between narrative and reality. While headlines point to a meaningful slowdown in FEOC-

related activity, market behavior reflects continued engagement across developers, OEMs, and

investors. Transactions are progressing, albeit with added complexity. The primary constraint is not

demand, but execution friction driven by uncertainty around FEOC compliance and, more acutely,

insurability within the tax credit insurance market

Insurance capacity remains limited, with a small pool of providers underwriting FEOC exposure.

This has pushed premiums higher, typically 4–5% and up to 8–9% for more complex deals,

while pressuring tax credit pricing below 90c in some cases. Importantly, this dynamic appears

transitional rather than structural. Conversations point to parallels with early domestic content

implementation, where initial friction gave way to standardization. Market participants are working