Tax Asset Utilization · Structural Advantage

The most protected structure
in the tax credit market.

TAU is not just a better economic outcome — it is a structurally safer instrument. The valuation of the energy credits is independently appraised and professionally insured. The §162 deduction mechanics are documented and CPA-insured. And four independent layers of protection stand behind every transaction.

No better protection exists in the ITC and tax equity market

Why the structure matters before protection does

Traditional Approach

ITC Transfer
(§6418)

  • ✕Investor owns the credit — carries full audit risk
  • ✕5-year recapture tail on investor's return
  • ✕Bridge financing required — 90–120 day gap
  • ✕Cash consideration — IRS benchmarks against cost
  • ✕Market pricing 90–95¢ on the dollar
  • ✕One-off transaction with no ongoing program

Traditional Approach

Tax Equity
Partnership Flip

  • ✕Partnership exposure — BBA audit risk
  • ✕Complex §704(b) allocation mechanics
  • ✕5-year recapture tail inside the partnership
  • ✕Requires equity capital contribution
  • ✕Ongoing legal and operational obligations
  • ✕Minimum transaction size typically $20M+

Four-Layer Protection Stack

Every element of TAU covered.
By the professional who determined it.

TAU uses non-cash NRGSC consideration — appraised fair market value with no open-market benchmark. Our protection structure places each risk exactly where it belongs: on the credentialed professional who made the determination, backed by their professional liability policy. The valuation is insured by the appraiser. The §162 mechanics are insured by the CPA. Nothing is circular.

01

NRGSC Valuation Coverage

NRGSC valuation insured by the appraiser

IntegriPoint Valuation Services carries $5 million per-incident professional liability insurance covering any IRS challenge to the USPAP-compliant appraisal of the NRGSC consideration. In a non-cash transaction, the appraised fair market value is everything — it establishes the cost basis, the deduction, and the documented exchange. The appraiser's professional liability is therefore the precisely correct instrument to backstop that risk, held by the professional who made the determination.

$5M per-incident · Covers NRGSC valuation and FMV determination
02

§162 Deduction Coverage

§162 deduction mechanics insured by the CPA

The CPA firm carries $5 million per-incident professional liability insurance covering the tax mechanics of every TAU transaction — specifically the §162 ordinary and necessary business deduction, the §61 income recognition pair inside htpNRG, and the full documentation package supporting that treatment. The policy covers the CPA's work product. No single TAU transaction exceeds $5 million, making this coverage sufficient to make any investor whole on any transaction in the program.

$5M per-incident · Covers §162 deduction and CPA documentation
03

Program Cash Reserve

First-loss buffer before insurance is triggered

Aeon Capital maintains a dedicated cash reserve as a first-loss layer against any claim. The intent is to resolve disputes cleanly and quickly — before professional liability coverage is ever triggered. Investors do not wait for an insurance claims process. The reserve moves first.

First-loss · Resolves before insurance is triggered
04

Credit Replacement from Ongoing Production

The layer no one-off developer can offer

htpNRG is not a single project — it is an ongoing enterprise continuously generating new tax credits across a national portfolio of hotel solar installations. If the first three layers do not fully resolve a claim, htpNRG delivers current-year production credits to the investor. Those credits eliminate the investor’s current-year tax liability dollar-for-dollar — freeing the cash they would otherwise have spent on taxes to cover any residual exposure from the prior-year transaction. The investor is made whole in real economic terms, in the current year, without litigation and without waiting. By the time a 2025 transaction reaches audit in 2029, the §50 recapture schedule already reduces maximum exposure to 20% of the original credit amount. htpNRG’s 2029 production covers that gap entirely through preserved cash — not a promise.

Unique to Aeon Capital
Live credit pipeline · No single-project developer can offer this

No better protection exists
in the tax credit market.

Four independent layers protecting the valuation of the energy credits and the mechanics of the §162 deduction. A live credit replacement pipeline no single-project developer can match. This is what institutional-grade protection looks like.

Talk to Archer → Contact the Deal Team