Inaugural Issue
Issue 1
July 2026
From Our Founders
Welcome to Footnote Magazine
One of Reunion's company values is "Read the Footnotes," a reminder that details truly matter in the world of tax and energy project finance. A footnote can determine whether a corporation is able to utilize energy tax credits in their current tax year, or whether a technology qualifies for favorable treatment under IRS rules. The clean energy tax credit market rewards precision, and getting it right often requires diving into the footnotes.
We started Reunion because we believe that financial and energy professionals deserve a detail-obsessed partner who has scrutinized the statute, regulations, and guidance — and who has executed enough transactions to know where things can go wrong. Even after closing more than $7.5 billion in transfers, we're still adapting as new credit structures emerge and regulations evolve.
Footnote Magazine is an effort to share what we're learning with corporate tax leaders, energy developers, attorneys, finance professionals, and others navigating policy and market complexity. Each issue of Footnote will go deep on the questions that matter. We will not oversimplify.
The name felt right. We've spent years reading the footnotes. With your help, we now have the chance to write them as well.
We look forward to collaborating with you,
Andy Moon and Billy Lee
Co-Founders, Reunion
Inside
- Insights from 6,000 Public Company Filings Insights p. 4
- A Real-World Case of Energy Tax Credit Recapture Research p. 8
- Q&A with Tom Reichart Vice President of Tax at PSEG Client Spotlight p. 12
- Compliance Corner Compliance Corner p. 14
- Q&A with Dora O'Donoghue Structured Finance at RWE Client Spotlight p. 16
- 5 Notable Numbers Numbers That Are Catching Our Eye p. 18
- PWA Compliance Pitfalls Prevailing Wage and Apprenticeship p. 19
- Q&A with Reunion's Connie Chern Head of Transactions Speed Round with the Reunion Team p. 21
- How Energy Storage Became Cheap Technology Breakthroughs p. 22
- A Case Study: Structuring a $30M §45Z Transaction Case Study p. 26
- §45Q Outlook: An Emerging Credit Carbon Capture p. 28
- Footnote Quiz Footnote Quiz p. 31
On the Market
Featured tax credit opportunities
The following is a curated and vetted selection of tax credit opportunities available through Reunion. We source available credits directly through our relationships with leading U.S. clean energy developers, manufacturers, and project sponsors. Our in-house experts review each opportunity for documentation quality and compliance readiness before bringing it to prospective buyers.
Details are current as of publication (July 2026); availability is subject to change. To inquire about these projects or explore alternative options, contact us at footnote@reunioninfra.com.
| Project | Tax Credit Amount | Credit Type | Credit Support | Technology | PWA | FEOC |
|---|---|---|---|---|---|---|
| 2025 Production Tax Credits | ||||||
| Project name withheld | $10M | §45X | Tax credit insurance | Advanced manufacturing | N/A | N/A |
| Project name withheld | $300M | §45X | "IG-like" parent guaranty | Advanced manufacturing | N/A | N/A |
| 2025 Investment Tax Credits | ||||||
| Project name withheld | $45M | §48E | Tax credit insurance | Residential solar + storage | N/A | N/A |
| Project name withheld | $80M | §48, §48E | Tax credit insurance | Community solar | Compliant | N/A |
| Project name withheld | $15M | §48 | Tax credit insurance | Utility-scale solar | Compliant | N/A |
| Project | Tax Credit Amount | Credit Type | Credit Support | Technology | PWA | FEOC |
|---|---|---|---|---|---|---|
| 2026 Production Tax Credits | ||||||
| Project name withheld | $50M | §45Q | IG parent guaranty | Carbon sequestration | Compliant | Compliant |
| Project name withheld | $75M | §45 | IG parent guaranty | Utility-scale solar | Compliant | N/A |
| Project name withheld | $300M | §45, §45U | IG parent guaranty | Utility-scale solar, onshore wind, nuclear | Compliant | N/A, Compliant |
| 2026 Investment Tax Credits | ||||||
| Project name withheld | $75M | §48C | Tax credit insurance | Biogas | Compliant | N/A |
| Project name withheld | $100M | §48 | IG parent guaranty | Battery storage | Compliant | N/A |
| Project name withheld | $210M | §48 | Tax credit insurance | Utility-scale solar | Compliant | N/A |
| Project | Tax Credit Amount | Credit Type | Credit Support | Technology | PWA | FEOC |
|---|---|---|---|---|---|---|
| 2027 Production Tax Credits | ||||||
| Project name withheld | $200M | §45X | IG parent guaranty | Critical minerals | N/A | Compliant |
| Project name withheld | $300M | §45Z | Tax credit insurance | Ethanol production | Compliant | Compliant |
| Project name withheld | $400M | §45 | IG parent guaranty | Utility-scale solar, onshore wind | Exempt, Compliant | N/A |
| 2027 Investment Tax Credits | ||||||
| Project name withheld | $400M | §48, §48E | IG parent guaranty | Utility-scale storage | Compliant | Compliant |
| Project name withheld | $1,000M | §48 | Tax credit insurance | Utility-scale solar + storage | Compliant | N/A |
On the Road
On the Road
Upcoming events where you can connect with Reunion
-
September 2-3
Carbon Capture USA
Houston
-
September 9-10
Power Forward
San Francisco
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October 18-21
Tax Executives Institute
Nashville
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November 5-6
Novogradac Fall Renewable Energy Conference
Washington, D.C.
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November 16-19
RE+
Las Vegas
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June 18-19 past
NRF Energy Finance Conference
Half Moon Bay, CA
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June 23-24 past
SEIA Finance Conference
New York
Will we see you there? Give us a heads up at footnote@reunioninfra.com.
Our new look
We recently refreshed the Reunion brand. Our new visual identity reflects a simple belief: buyers and sellers in complex transactions deserve speed, care, and reliable outcomes. We're a team of seasoned clean energy professionals who provide both the rigor and hands-on attention to achieve that purpose.
Our logo is the clearest expression of our new brand. The outer structure of the logo is precise and geometric, a nod to the attention to detail our work demands. The inner curve signals the personalized and human touch that we bring. The dual "r" motif evokes a bridge, which symbolizes connection and trust between parties. The balance is intentional: connecting capital to infrastructure, and people on each side of a transaction to each other.
We hope this resonates with partners we've worked with, and those we hope to work with in the future.
Reunion is hiring
Join us in scaling one of clean energy finance's most exciting and impactful companies — with competitive compensation and full benefits.
Masthead
Reunion
Andy Moon
Co-Founder and CEO
Billy Lee
Co-Founder and President
Alessio De Falcis
Head of Commercial Strategy
Alex Melehy
Head of Product & Engineering
Connie Chern
Head of Transactions and Finance
Denis Cook
Director, Business Development and Research
Footnote
Barry Fischer
Editor
DJB Design
Design and Art Direction
Mosaic
Printing and direct mail
Contact Reunion
PO Box 29428, San Francisco, CA 94129
Adobe Stock photography by: Thiradet Khlangkun, Leo Lintang, Ivan Milovanov, Peter Jesche, amnach, azrisuratmin, piyaphun, Ocskay Mark, Robson90, The Desert Photo, Chris Chambers
In some instances, AI assistance was used to support content in Footnote.
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