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State Credits Are Creating Two Different Deals While Filling Gaps Left by Federal Tax Credit Programs

By Christopher Renda, Transaction Associate - Capital Markets Group

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Across recent executions, we’re seeing a consistent pattern:

Two projects with similar state credit awards underwriting as fundamentally different deals once they move into financing, sometimes within the same state.

The difference is not the award.
It’s how that award converts into capital.

What This Looks Like in Market

In structures where credits are delivered upfront or near closing, developers are generally accepting discounted pricing in exchange for:

  • immediate proceeds
  • minimal bridge exposure
  • cleaner execution

In contrast, where credits are streamed or tied to certification or K-1 timing over a decade, the same nominal award introduces:

  • multi-year bridge exposure
  • meaningful interest carry
  • additional reserves and structuring

This is not a marginal difference. It is a different capital stack.

Where This Is Showing Up

Most clearly in:

  • programs with delayed monetization, where bridge becomes embedded rather than optional
  • transactions trading lower-priced early capital for higher-priced delayed capital
  • deals where bridge duration extends beyond initial underwriting, forcing late-cycle rework

This is showing up as:

  • revised sources and uses late in the process
  • resized permanent or soft debt
  • delayed partnership closings

How Developers Are Responding

Developers are not mispricing this, they are making deliberate tradeoffs.

In practice:

  • where upfront capital is available, it is often preferred—even at a discount
  • where it is not, bridge is underwritten more conservatively than in prior cycles

The decision is increasingly driven by duration:

  • how long capital is outstanding
  • not just how much capital is raised

In effect, execution certainty is being discounted more heavily than net proceeds.

A Simple Example

Two comparable structures:

  • Structure A: $8MM proceeds, funded near closing
  • Structure B: $9.4MM proceeds, funded over time with a 36-month bridge at 10%

Structure B is superior on pricing.

In execution, once:

  • Carry
  • Reserves
  • Duration risk

are incorporated, the difference in proceeds narrows materially.

Developers are often choosing Structure A, not because it always maximizes proceeds, but because it reduces execution risk and simplifies an already constrained capital stack.

What Moves a Deal

The relevant question is:

“What does the structure require the deal to carry before it resolves?”

That is where:

  • deals tighten
  • gaps re-emerge
  • closings get pushed

If you’re not already modeling credit efficiency after bridge and net pricing, then that’s something that will assist in helping you see the true value of the tax credit award in your state.

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