Credit Transfer Election (TRE)

An eligible taxpayer, which is generally any taxpayer that is not an applicable entity, that qualifies for an eligible credit under section 6418(f)(1)(A), may elect to transfer all or a portion of the credit to an unrelated third-party in exchange for cash. The parties negotiate and agree to terms and pricing. The election to transfer an eligible credit to an unrelated third-party is called a Credit Transfer Election (TRE). A TRE for any portion of an eligible credit can be made no later than the due date (including extensions of time) of the tax return for the taxable year for which the credit is determined. Any such election, once made, is irrevocable.

For each TRE, an eligible taxpayer must pre-register and receive a registration number from the IRS before filing a tax return making a TRE. See Pub 5884 for more information. See the table below for a list of TRE eligible credits.

TRE Transferable Credit Name

Alternate Fuel Vehicle Refueling Property

Renewable Electricity Production for Qualified Facilities placed in service after December 31, 2022

Carbon Oxide Sequestration for Qualified Facilities from equipment placed in service after December 31, 2022

Zero-Emission Nuclear Power Production

Clean Hydrogen Production Credit for facilities placed in service after December 31, 2012

Advanced Manufacturing Production

Clean Electricity Production

Clean Fuel Production

Clean Energy

Qualifying Advanced Energy Project

Clean Electricity Investment

For tax periods after 202212, all applicable tax forms have been updated with EPE/TRE lines, therefore no special RPCs will be assigned.

For tax periods 202201-202212, the taxpayer should indicate "IRA22TRE" on Form 3800 or an attachment at the top of the return. A TRE can be identified on the claimant’s tax account with an RPC "K" .