Time is running short for solar developers who want to keep their federal tax credits. Between interconnection queues, equipment lead times, new tariffs and foreign entity of concern (FEOC) rules, getting a project over the 2027 line takes more than a calendar reminder.
Those pressures were the focus of Canary Media’s forum on October 22, “Hold onto Your Tax Credits: How to Get Ahead of the 2027 Deadline.” Solar projects that did not begin construction by July 4, 2026 must be placed in service by December 31, 2027, or lose the 45Y/48E credit. Four industry experts spent an hour on what it takes to get there.
Speaker Lineup:
- Heather Cooper – Partner, McDermott Will & Schulte (tax and compliance)
- Rohit Patil – Sr. Director of Engineering, New Leaf Energy (development and execution)
- Ravi Manghani – Senior Director of Strategic Sourcing, Anza Renewables (procurement and supply)
- Kleber Facchini – Applications Engineer, SolarEdge Technologies (equipment and customer demand)
- Maria Virginia Olano – Moderator, Canary Media
The Finish Line is Fuzzier Than the Deadline
Hitting the December 31, 2027 deadline depends on what counts as “placed in service,” and that is less clear than it sounds. Heather Cooper of McDermott Will & Schulte explained that the IRS judges “placed in service” with five weighted factors rather than a checklist, which means “it’s really hard, even as expert tax practitioners, to determine when you are placed in service with certainty.”
Her advice is to think in windows: a date by which a project might be in service, and a later one by which it definitely is. She also shared a tactic that investors and insurers have grown comfortable with when utility approval is slow.
The Race is Against the Utility and the Supply Chain
Rohit Patil of New Leaf Energy warned that “the placed-in-service deadline doesn’t necessarily turn a marginal project into a good project,” and that the bottleneck is typically the utility’s energization and commissioning. Kleber Facchini of SolarEdge said that is already changing behavior: customers are shifting toward rooftop projects, which connect to the distribution grid faster than rural ground-mount sites.
Equipment brings its own dates. New Section 232 tariffs take effect December 4, and Ravi Manghani of Anza Renewables advised customers to lock in modules before then, because “any sort of modules that land after that date will cost you more.” Transformers have long lead times, and compliant batteries remain tight even as inverter supply looks ample.
Compliance and Cost Dictate Whether the Credit is Worth Keeping
Foreign entity of concern (FEOC) rules are, in Cooper’s words, “the piece that I would say our clients are struggling the most with.” She explained how ordinary contract boilerplate can create credit risk, and Manghani noted that key guidance is still pending.
He then put numbers on what staying compliant costs, from modules to storage to tax equity, before offering a reality check: “ITC is not the end-all, be-all for any project.” Some projects, the panel suggested, may pencil out better without the credit.
Start with Your Files and Keep Records
Cooper’s first move for teams that missed July 4 is to look backward, because work already done may count as beginning construction. Beyond that, she said, “there are things definitely folks should be doing now,” from documenting continuous effort to locking in equipment.
The panel closed on keeping schedules flexible, so a cheaper option can be swapped in if the policy picture changes, and the importance of keeping thorough records.
Dates to Watch
Key dates for solar projects aiming to meet the 2027 deadline:
| Date | What Happens | Why It Matters |
|---|---|---|
|
July 4, 2026 |
Begin-construction deadline for solar and wind (passed) |
Projects that began on or before it escape the 2027 cutoff |
|
December 4, 2026 |
Section 232 tariffs and minimum import price take effect |
Modules landing after this date will cost more |
|
December 24, 2026 |
DOE guidance tied to the executive order expected, per Manghani |
Recheck supplier eligibility |
|
December and January |
Treasury guidance on effective control anticipated, per Manghani |
Could change vendor status under FEOC rules |
|
February 9 – 11, 2027 |
IESNA Flagship, San Diego |
“Hit Your COD, Keep Your Credit” session |
|
December 31, 2027 |
Placed-in-service deadline for solar and wind projects that did not begin construction by July 4, 2026 |
Credits go away if missed |
|
December 31, 2030 |
Continuity safe harbor end date for projects that began construction in 2026 |
End of the fourth calendar year after construction began |
Missed the Live Forum? Watch the Full Recording
The full forum runs about an hour and goes well beyond this recap, including Manghani’s cost breakdown for modules, storage and tax equity, Cooper’s explanation of how FEOC contract language can put credits at risk, and the practical tactics teams are using to show a project is in service.
Watch the recording here.
Continue the Conversation in San Diego
If this recap raised questions, bring them to San Diego. The session, “Hit Your COD, Keep Your Credit,” taking place at ISENA Flagship in San Diego, February 9 to 11, 2027, picks up where the forum left off.
The panel will dig into what “placed in service” requires, how domestic content and approved vendor decisions ripple into financing, FEOC guidance including IRS Notice 2026-15, and the battery supply gap’s threat to timelines.
The forum panel’s four experts, Cooper, Patil, Manghani and Facchini, are all on the session’s speaker list, joined by moderator Daniel Finn Foley, Director of Energy Storage, Market Intelligence at Intertek. Attendees will leave knowing the steps developers, EPCs and installers should be locking in right now.
See what else is on the agenda by browsing the full lineup of conference sessions at IESNA Flagship.
