An early-20th-century American schoolhouse and works building being raised side by side, dissolving through copper and cobalt light into a modern training institute standing beside an AI factory

The idea behind this page

The greatest profits are found, not earned.

Our founder has always said it that way. What he means is that the most valuable thing a company can find is an incentive program built to develop and build that company in parallel with its community — not one at the expense of the other.

Because that arrangement pays twice — the value of the community, and the value the community rewards the company with. The community gains something real and permanent: trained residents, wages, a school, infrastructure it keeps. And the company is rewarded for having created it. Neither is earned in the ordinary way. They are found.

Active credits catalogued

Workforce & education programs

Rungs, high school to university

Moves every state runs

The mechanism that closes the loop

Five times the credit. One condition.

This is the part most people never get told, and it is the single most important fact on this page. A project that misses the condition earns the base rate. A project that meets it earns five times that. The condition is prevailing wage and registered apprenticeship — in other words, the credit that finances the plant is priced on whether you train people.

Congress made workforce training a requirement of the capital stack. Not a bonus, not a community-benefits agreement negotiated at the end — a gate. Which means the training institute on a SAVRN campus is the compliance engine for the factory's financing. Take the institute away and the economics of the power plant change by a factor of five.

A 1940s machine-shop apprentice beside a master tradesman dissolving into a modern apprentice at medium-voltage switchgear — A century apart, the same arrangement: someone paid to learn the work beside someone who already knows it.

The campus registers apprenticeships

Standards filed with the Department of Labor: the occupation, the wage ladder, the on-the-job hours, and the classroom hours that go with them.

Residents get hired and paid to learn

An apprentice earns a wage from the first day. The classroom instruction is delivered by the local community college.

The project clears the wage and apprentice gate

With prevailing wage met and apprentices on site, the energy credits pay at the full rate rather than the base rate.

The credits fund the programs

The value that gate unlocks is what pays for the institute — so the community keeps the training, and no resident is asked to fund it or to pay tuition for it.

The apprentice is not the beneficiary of the project. The apprentice is the reason the project pencils.

That is not a slogan. It is how the statute is drafted. The same rule appears across the energy credit family — the carbon capture credit, for one, runs from a base rate to five times that rate on exactly this condition, and our own catalog record for it says so in those words.

How the stack is organized

Five layers, assembled in order.

People tend to talk about incentives as a pile. They are not a pile. They sit in layers, and the layers depend on each other. Compliance sits underneath everything, because it sets the rate on everything above it.

Stacked vellum drawing sheets edge-lit in amber dissolving into four glowing exploded strata of a modern energy and compute campus — Foundation, power, storage, compute. The layers are assembled in order, and compliance sets the rate on all of them.

16 entries

Federal capital

Credits and deductions earned on what gets built — generation, storage, manufacturing, research, and the depreciation that shelters it.

10 entries

Federal people

Credits and programs earned on who gets hired and trained. This is the layer most projects leave on the table.

28 entries

State and local

Property tax, sales tax, training money, financing, and the negotiated award. Five moves, run under different names in every state.

3 entries

Monetization

How a credit becomes cash: direct pay, transfer, or a tax-equity partner.

6 entries

Compliance

The conditions attached to the money. These are not paperwork — they are the multiplier.

What gets built, and why

Each technology, and the incentive that makes it the obvious choice.

This is the clearest way to see the method working. In almost every case there is a conventional answer and a better answer, and the tax code has already put its thumb on the better one. We are not being virtuous. We are reading.

A 1930s powerhouse flywheel and belts dissolving into a silent modern lineup of battery storage cabinets and fuel cell modules with copper busbars — The conventional answer on the left. The answer the tax code pays for on the right. Same job, no combustion, no noise.

Fuel cells

Firm power made on site, without a combustion turbine.

Solid oxide fuel cells convert fuel to electricity electrochemically rather than by burning it. The campus makes its own power at the point of use, which removes the interconnection queue from the schedule and removes the utility bill from the operating model.

What it means for the community. No combustion means no combustion emissions profile at the fence line, and the plant is quiet. A community gets the jobs and the tax base without the stack.

§48E§45Q§168(k)

Fuel cells are named in the § 48E eligible technology set.

Battery energy storage at medium voltage

BESS on the medium-voltage bus, in place of diesel generators.

A battery energy storage system tied in at medium voltage, typically the same distribution class as the campus bus, carries the load through a power disturbance, meaning a voltage sag or a momentary outage, and keeps the site running through a down event. It also shifts load, firms the on-site generation, and can sell services back to the grid.

What it means for the community. This is the clearest example of an incentive changing what gets built. A diesel generator farm is the conventional answer to a down event: it earns no federal credit, needs fuel stored on site, and has to be test-run on a schedule the neighbors hear. A battery system does the same job, earns the investment credit as standalone storage, and makes no noise. The tax code makes the better neighbor the cheaper option.

§48E (Storage)§168(k)

Energy storage qualifies for § 48E on its own, without being paired to a generator.

Geothermal

Heat from the ground, for power or for cooling.

Geothermal resources can generate electricity where the resource supports it, and ground-source loops can reject heat far more efficiently than air-cooled equipment almost anywhere else.

What it means for the community. A ground loop uses no water to reject heat, which matters in every county where water is the reason a data center gets voted down.

§48E§168(k)

Geothermal is named in the § 48E eligible technology set.

Carbon capture

Capture the CO2 the on-site generation produces.

On-site generation running on natural gas produces a concentrated carbon dioxide stream, which is materially easier and cheaper to capture than dilute flue gas. Captured CO2 goes to secure geologic storage, enhanced recovery, or qualified utilization.

What it means for the community. It is the difference between a project that adds emissions to a county's inventory and one that does not.

§45Q

§ 45Q pays per metric ton for twelve years, and the credit can be taken as cash under § 6417 for the first five.

Heat capture and reuse

The waste heat becomes someone's heating bill, eliminated.

Liquid-cooled compute rejects heat at a temperature that is actually useful. Captured and piped, it can heat the Institute, a community center, a greenhouse, or a municipal building instead of being thrown into the air.

What it means for the community. A data center's waste heat is normally a nuisance. Captured, it is a permanent reduction in a public building's operating cost, and it is the most legible benefit on the whole campus to a resident who does not care about tax law.

§179D

§ 179D rewards the efficiency of the buildings that receive the heat.

Manufacturing on site

Build the components, do not just install them.

Fabricating modules, enclosures, and power components on the campus turns a construction project into a permanent manufacturing employer, and brings a second and separate set of incentives with it.

What it means for the community. Construction jobs end. Manufacturing jobs do not. This is what changes a project from a two-year event into an employer.

§45X§48CTX §151.318CA §6377.1

Manufacturing carries its own production credit and its own state equipment exemptions.

Research and development

The work of making it run better is itself creditable.

Model development, cooling engineering, and control-system work are qualified research. The credit offsets tax, and the expensing provision lets the cost be deducted immediately rather than amortized.

What it means for the community. This is the line that connects the factory to the university. Sponsored research is creditable to the sponsor and career-making for the faculty and graduate students who do it.

§41§174CA R&D

§ 174 immediate expensing was restored, which materially improved the cash timing on research spend.

The education ladder

One path, entered at any age. Nothing has to be repeated.

A community does not need a training program. It needs a ladder — where the work a fifteen-year-old does counts toward the credential a nineteen-year-old earns, which counts toward the degree a twenty-four-year-old finishes, without anyone paying twice for the same learning. Federal law already contemplates this. The Perkins statute asks for programs of study that connect high school to college. Apprenticeship hours carry. Associate degrees articulate. The pieces exist; they are just rarely assembled by one operator.

Rung 1 — High school

High school

Grades 9 to 12

A student takes a career and technical sequence written as a Perkins program of study, earns college credit through dual enrollment, and can enter a youth apprenticeship and start drawing a wage before graduating.

Paid for by

Perkins VState CTE fundingDual-enrollment agreementsEmployer wages in youth apprenticeship

What carries forward

Articulated college credit, an industry certification, and on-the-job hours that count toward a registered apprenticeship. The student arrives at community college already partway through it.

Rung 2 — Community and technical college

Community and technical college

Certificate through associate degree

Short certificates stack into longer ones and then into an associate degree. The college also delivers the classroom instruction that accompanies a registered apprenticeship, so a working apprentice and a full-time student sit in the same room.

Paid for by

Workforce PellFederal PellWIOA training accountsState customized training fundsState need-based training fundsVA OJT and apprenticeship

What carries forward

An associate degree that transfers into a bachelor's program under an articulation agreement, plus a credential the employer already recognizes because the employer helped write it.

Rung 3 — University

University

Bachelor's and beyond

The associate degree transfers in. The student finishes a bachelor's while working, often with the employer paying. Research faculty work on the factory itself — power systems, cooling, model performance — and graduate students work alongside them.

Paid for by

Employer tuition sponsorshipTransfer articulation§ 41 and § 174 research credits on the sponsored work

What carries forward

A degree, a research record, and a career that never required leaving the community to start.

How states differ, and how they don't

Fifty different statutes. Five recurring moves.

The federal layer is identical in all fifty states. The state layer looks different everywhere until you have done it a few times, and then it stops looking different. Nearly every state runs the same five instruments under its own names and its own thresholds. Knowing that is what makes a campus portable: we are not learning a new game in each state, we are filling in the same five slots.

A 19th-century surveyor's brass transit and chain dissolving into a glowing three-dimensional lattice of land parcels holding a modern campus model — Siting land is old work. The instruments changed; the five things a state offers did not.

Property tax abatement or payment in lieu

The local taxing units agree to abate or fix property tax on new investment for a set term, in exchange for investment and job commitments.

Texas Chapter 312 and HB 5 · Nevada real and personal property abatements

Sales and use tax exemption on equipment

Equipment used in manufacturing or qualifying operations is exempted from sales tax at purchase, which is a first-year cash saving on a capital-heavy build.

Texas § 151.318 · Nevada capital equipment abatement · California § 6377.1 partial exemption

A workforce training fund

State money to train the workers the project hires, delivered through a public college.

Texas Skills Development Fund · Nevada Train Employees Now · California Employment Training Panel

A financing vehicle

Access to tax-exempt or below-market capital for qualifying industrial and energy assets.

Texas industrial revenue bonds · Nevada industrial development revenue bonds · California C-PACE

A discretionary deal fund

A negotiated award the state or city can offer at its discretion to win a project, usually tied to jobs and capital commitments.

California Competes · Texas Chapter 380 and 381 agreements · Texas Enterprise Zone Program

Catalogued in detail so far — additional states are added as campuses are sited.

Texas

No state corporate income tax. Heavy use of property-tax abatements (Chapter 312), school-district HB 5 PILOT, and the §151.359 data center sales-tax exemption.

TX §151.359TX QDC SUT Exemption
TX §151.318TX Mfg SUT Exemption
TX Ch 312TX Ch 312 Abatement
TX HB 5TX HB 5 School PILOT
TX Ch 380/381TX 380/381 EDA
TX EZPTX Enterprise Zone
TX SDFTX Skills Dev Fund
TX IRBTX IRB

Nevada

No state corporate income tax. NRS 360.754 data center abatement, NRS 701A renewable energy abatement, modified business tax (MBT) discount programs.

NV NRS 360.754NV Data Center Abatement
NV NRS 701ANV Renewable Abatement
NV MBTNV MBT Abatement
NV SUT AbatementNV SUT Abatement
NV PPT AbatementNV PPT Abatement
NV RPT AbatementNV RPT Abatement
NV TENNV TEN
NV IDRBNV IDRB

California

Strong R&D credit, GO-Biz California Competes discretionary award, partial sales tax exemption on manufacturing/R&D equipment, employment training reimbursement.

CA CompetesCA Competes
CA R&DCA R&D
CA §6377.1CA Mfg SUT
CA ETPCA ETP
CA HRTPCA HRTP
CA C-PACECA C-PACE

Virginia

The largest data-center market in the world. The §58.1-609.3(18) sales-and-use tax exemption is the anchor — and, like the federal energy credits, it is wage-gated: every qualifying job must pay 150% of the locality's prevailing average wage.

VA §58.1-609.3(18)VA Data Center SUT Exemption
VA BPPVA Local BPP Rate
VA VJIPVA VJIP
VA VTAPVA Talent Accelerator
VA COFVA Opportunity Fund
VA C-PACEVA C-PACE

The library

Every incentive, explained one at a time.

This is the working reference, not a summary of one. Each entry carries its statutory authority, how the rate is actually structured, what has to be true to claim it, how it converts to cash, and how SAVRN applies it. These are the same records our financial models are built from — the page and the model read one file, so a number quoted here is the number the model runs.

A wall of blank-spined leather ledger volumes and a card catalog dissolving into an orderly grid of glowing translucent record panels — Every entry below carries its authority, its rate, its conditions, and how it converts to cash.

§48E

Clean Electricity Investment Tax Credit

30% base · +10pp domestic content · +10pp energy community · +10pp low-income. Max 50%.

Federal — Investment Tax CreditsDetail +

Authority: 26 U.S.C. §48E
How the rate works: 30% base · +10pp domestic content · +10pp energy community · +10pp low-income. Max 50%.
What qualifies: Any zero-emissions electricity generation or energy storage technology placed in service after Jan 1 2025. Tech-neutral successor to §45/§48. Includes wind, solar, geothermal, nuclear (advanced), fuel cells, qualifying battery storage, and movable modular generation/storage assets under the Whiteco Industries 6-factor test.
What has to be true: Prevailing wage + apprenticeship throughout construction and operation to claim full 50% rate. ≥50% domestic-content sourcing for +10pp adder. Energy community designation by Treasury for +10pp adder. FEOC supply-chain certification annually.
How it becomes cash: §6417 direct pay (tax-exempt only — for-profits: limited), §6418 transferability (single transfer for cash, ~92-95% of face value typical).
Duration: 5-year recapture window post-placement (linear vesting). Credit earned at placed-in-service date.
How SAVRN uses it: IntelliFlex Block (movable modular compute platform) qualifies as personal property under Whiteco 6-factor test. DRUPS flywheel energy storage qualifies under storage technology category. OBBBA §48E(j) provides a dedicated flat 30% ITC specifically for qualified fuel-cell property — the primary hook for SAVRN's solid-oxide on-site generation.

§48E (Storage)

Energy Storage Technology — §48E Standalone

30% base + 10pp domestic content + 10pp energy community. Same bonus stack as §48E generation.

Federal — Investment Tax CreditsDetail +

Authority: 26 U.S.C. §48E(c)(3)
How the rate works: 30% base + 10pp domestic content + 10pp energy community. Same bonus stack as §48E generation.
What qualifies: Stationary energy storage with ≥5 kWh capacity. Battery, thermal, mechanical (flywheel), gravity, pumped hydro, hydrogen storage, compressed-air. Standalone storage credit since IRA — no longer must co-locate with generation.
What has to be true: Same wage/apprenticeship rules as §48E generation. ITC basis allocated separately from co-located generation.
How it becomes cash: §6418 transferability available. Direct pay only for tax-exempt entities.
Duration: 5-year recapture window.
How SAVRN uses it: DRUPS battery-free Diesel Rotary UPS flywheel storage in each IntelliFlex Block qualifies as energy storage technology. Per-Block basis ~$15MM × 30% = $4.5MM/Block ITC.

§45Y

Clean Electricity Production Tax Credit

1.5¢/kWh base (2024 dollars, inflation-adjusted) × multipliers. +10pp domestic content +10pp energy community.

Federal — Production Tax CreditsDetail +

Authority: 26 U.S.C. §45Y
How the rate works: 1.5¢/kWh base (2024 dollars, inflation-adjusted) × multipliers. +10pp domestic content +10pp energy community.
What qualifies: Zero-emissions electricity generation placed in service after Jan 1 2025. Tech-neutral. Operator elects §48E ITC OR §45Y PTC at placement — not both for same asset.
What has to be true: Same wage/apprenticeship/domestic-content rules as §48E. 10-year production window from placement.
How it becomes cash: §6418 transferability — credits transferred year by year as earned. §6417 direct pay tax-exempt only.
Duration: 10-year production credit window per asset.
How SAVRN uses it: Alternative to §48E ITC. For projects with steady high-utilization clean generation, §45Y over 10 years can exceed up-front §48E ITC. SAVRN typically elects §48E for capital recovery speed.

§45V

Clean Hydrogen Production Tax Credit

Tiered by lifecycle GHG intensity: $3.00/kg (≤0.45 kgCO₂e/kgH₂) · $1.00/kg · $0.75/kg · $0.60/kg. With wage/apprenticeship: full rate. Without: 20% of…

Federal — Production Tax CreditsDetail +

Authority: 26 U.S.C. §45V
How the rate works: Tiered by lifecycle GHG intensity: $3.00/kg (≤0.45 kgCO₂e/kgH₂) · $1.00/kg · $0.75/kg · $0.60/kg. With wage/apprenticeship: full rate. Without: 20% of rate.
What qualifies: Hydrogen produced at a qualifying facility placed in service before Jan 1 2033. Lifecycle GHG measured under 45VH2-GREET (Argonne National Lab). Three-pillars rule: temporal matching, deliverability, additionality of clean electricity inputs.
What has to be true: Three-pillars compliance for electrolytic H₂. Annual GHG verification by qualified verifier. Wage/apprenticeship for full rate.
How it becomes cash: §6418 transferability (annual). §6417 direct pay tax-exempt only.
Duration: 10-year production window from placement.
How SAVRN uses it: Future Phase 2 hydrogen production at SAVRN sites. Solid Oxide Electrolyzer Cell (SOEC) operation in CleanFlex H₂/CHP loop. Currently scoped at $1-3/kg depending on lifecycle profile.

§45Z

Clean Fuel Production Credit

Up to $1/gallon non-aviation, $1.75/gallon SAF. Sliding by emissions reduction vs. baseline.

Federal — Production Tax CreditsDetail +

Authority: 26 U.S.C. §45Z
How the rate works: Up to $1/gallon non-aviation, $1.75/gallon SAF. Sliding by emissions reduction vs. baseline.
What qualifies: Transportation fuel produced at a qualified facility with lifecycle GHG ≤50 kgCO₂e/mmBTU. Includes renewable diesel, SAF, renewable natural gas, hydrogen for fuel use.
What has to be true: Annual lifecycle GHG certification. Wage/apprenticeship for full rate. Fuel sold for use as transportation fuel.
How it becomes cash: §6418 transferability annually.
Duration: Effective 2025-01-01 through 2027-12-31 (current authorization).
How SAVRN uses it: Biorefinery output: cellulosic ethanol (energy cane intake) and biogas/digestate from anaerobic digestion. SAF pathway under development. CF-OPS-002 SOP governs production.

§45U

Zero-Emission Nuclear Power Production Credit

0.3¢/kWh base, reduced as gross receipts exceed thresholds. Wage/apprenticeship multiplier: 5×.

Federal — Production Tax CreditsDetail +

Authority: 26 U.S.C. §45U
How the rate works: 0.3¢/kWh base, reduced as gross receipts exceed thresholds. Wage/apprenticeship multiplier: 5×.
What qualifies: Existing zero-emission nuclear electricity generation. Designed to preserve operating nuclear fleet against early retirement.
What has to be true: Net electricity output verified by EIA. Sunset 2032-12-31 absent extension.
How it becomes cash: §6418 transferability.
Duration: Through 2032-12-31.
How SAVRN uses it: Not directly applicable to current SAVRN sites. Relevant if future SMR (small modular reactor) deployment scopes in.

§45Q

Credit for Carbon Oxide Sequestration

Base $17/metric ton (industrial & power capture) or $36/ton (direct air capture); multiplied 5× to $85/ton and $180/ton (DAC) when prevailing-wage + a…

Federal — Production Tax CreditsDetail +

Authority: 26 U.S.C. §45Q
How the rate works: Base $17/metric ton (industrial & power capture) or $36/ton (direct air capture); multiplied 5× to $85/ton and $180/ton (DAC) when prevailing-wage + apprenticeship (PWA) is met. OBBBA established rate parity: the top rate now applies across secure geologic storage, enhanced oil/gas recovery, and qualified utilization for facilities placed in service after 2025-07-04. Inflation-adjusted.
What qualifies: Carbon capture equipment at qualified industrial/power facilities and direct-air-capture facilities meeting minimum annual capture thresholds; captured CO2 must go to secure geologic storage, EOR, or qualified utilization.
What has to be true: PWA required to unlock the 5× rate. Secure-storage MRV documentation (EPA Subpart RR / 45Q(f)). Begin-construction deadline 2033-01-01. OBBBA prohibited-foreign-entity (PFE) restrictions apply to tax years beginning after 2025-07-04.
How it becomes cash: §6417 elective (direct) pay for the first 5 years — available to any taxpayer, not only tax-exempts; §6418 transferability preserved; otherwise general business credit with carryforward.
Duration: 12-year credit period from placed-in-service; 3-year recapture lookback if CO2 ceases to be stored.
How SAVRN uses it: SOFC / on-site natural-gas generation produces a concentrated, capturable CO2 stream; capture equipment on SAVRN's on-site power qualifies. Monetizable via §6417 direct pay (first 5 years) or §6418 transfer.

§41

Research & Experimentation Credit

Two methods. Regular: 20% of qualified research expenses (QREs) above base period. Simplified: 14% of QREs above 50% of prior 3-yr average.

Federal — R&D Credits & ExpensingDetail +

Authority: 26 U.S.C. §41 (Form 6765)
How the rate works: Two methods. Regular: 20% of qualified research expenses (QREs) above base period. Simplified: 14% of QREs above 50% of prior 3-yr average.
What qualifies: Qualified Research Expenses meeting the 4-part §41 test: (1) qualified purpose new/improved business component; (2) elimination of technological uncertainty; (3) process of experimentation; (4) technological in nature (engineering, physical, biological, computer science).
What has to be true: Contemporaneous documentation: project descriptions, technical uncertainties, experimentation, time tracking by activity. Form 6765 annually. §174 expensing required to claim §41 credit on same expenses.
How it becomes cash: Reduces tax liability. Carries forward 20 years. §6417 direct pay not available for §41.
Duration: Permanent provision.
How SAVRN uses it: AI model architecture, LLM training pipeline, immersion cooling thermal R&D, control-system experimentation, energy-flow optimization algorithms. Platform R&D estimated 9% of total revenue with ~50% qualifying.

§174

R&D Immediate Expensing — OBBBA Restored

100% immediate expensing in year incurred. Restored by OBBBA July 4 2025 (prior TCJA required 5-year domestic / 15-year foreign amortization 2022-2025…

Federal — R&D Credits & ExpensingDetail +

Authority: 26 U.S.C. §174
How the rate works: 100% immediate expensing in year incurred. Restored by OBBBA July 4 2025 (prior TCJA required 5-year domestic / 15-year foreign amortization 2022-2025).
What qualifies: All qualified research and experimentation expenditures. Broader than §41 QREs — includes overhead, support, and indirect costs of research activity.
What has to be true: Must elect §174 to claim §41 credit on same expenses. Contemporaneous expense tracking by project.
How it becomes cash: Tax deduction in year incurred — creates large NOL in heavy R&D years. NOL carries forward indefinitely (80% income limit per year post-TCJA).
Duration: Permanent under OBBBA.
How SAVRN uses it: Incremental tax shield estimated 9% of revenue × combined rate ~29.84% (Fed 21% + CA 8.84%). Major shield contributor in early years before platform reaches profitability.

§45S

Employer Credit for Paid Family and Medical Leave

12.5%–25% of wages paid during qualifying leave (12.5% at 50% wage replacement, rising to 25% at 100%). OBBBA premium method: alternatively up to 25% …

Federal — Employment & WorkforceDetail +

Authority: 26 U.S.C. §45S
How the rate works: 12.5%–25% of wages paid during qualifying leave (12.5% at 50% wage replacement, rising to 25% at 100%). OBBBA premium method: alternatively up to 25% of premiums paid for a PFML insurance policy.
What qualifies: Wages — or, post-OBBBA, PFML insurance premiums — for up to 12 weeks of qualifying family/medical leave per employee.
What has to be true: Written PFML policy required. OBBBA expanded eligibility: employees qualify at 6 months of service (was 12); part-time employees working ≥20 hrs/week are covered. Premium method detailed in IRS Notice 2026-28.
How it becomes cash: Nonrefundable general business credit (§38); no direct pay or transfer; 20-year carryforward / 1-year carryback.
Duration: Annual credit on qualifying leave wages or premiums.
How SAVRN uses it: SAVRN workforce benefits — paid-leave wages or PFML premiums qualify. Made PERMANENT and expanded by OBBBA, effective 2026 tax years.

§45X

Advanced Manufacturing Production Credit

Per-unit credit by component. Solar PV: 4¢/W modules, 7¢/W cells. Battery: $45/kWh cells + $10/kWh modules. Inverters: 11¢/W central · 6.5¢/W string. …

Federal — Manufacturing & Program CreditsDetail +

Authority: 26 U.S.C. §45X
How the rate works: Per-unit credit by component. Solar PV: 4¢/W modules, 7¢/W cells. Battery: $45/kWh cells + $10/kWh modules. Inverters: 11¢/W central · 6.5¢/W string. Critical minerals: 10% of production cost.
What qualifies: US-manufactured eligible clean-energy components: solar (modules, cells, wafers, polysilicon), wind (blades, nacelles, towers, offshore foundations), batteries (cells, modules, electrode active material), inverters, thermal management, power electronics, critical minerals refined or recycled domestically.
What has to be true: Manufacturing facility must be in US territory. Components must be sold to unrelated party or used in qualifying downstream production. No FEOC content in qualifying components.
How it becomes cash: §6418 transferability. §6417 direct pay tax-exempt only.
Duration: Phase-down begins 2030 (75%), 2031 (50%), 2032 (25%), 2033 sunset.
How SAVRN uses it: IntelliFlex Technologies (CleanFlex affiliate) manufactures thermal management modules, power electronics, and integrated DRUPS subsystems in North America. Per-Block §45X earnings ~$30-60MM depending on build schedule.

§179D

Energy-Efficient Commercial Buildings Deduction

Up to $5.00/sqft at maximum efficiency tier. Sliding scale by energy reduction vs. ASHRAE 90.1-2007 baseline.

Federal — Manufacturing & Program CreditsDetail +

Authority: 26 U.S.C. §179D
How the rate works: Up to $5.00/sqft at maximum efficiency tier. Sliding scale by energy reduction vs. ASHRAE 90.1-2007 baseline.
What qualifies: Commercial buildings (and government-owned buildings, designed by qualified person who can take the deduction). Energy-efficient interior lighting, HVAC, building envelope improvements.
What has to be true: Certification by qualified person under ASHRAE 90.1-2007 baseline. Prevailing wage and apprenticeship required for maximum deduction.
How it becomes cash: Tax deduction in year placed in service.
Duration: Permanent.
How SAVRN uses it: Training Institute building, control rooms, on-site office and operator facilities. High-efficiency LED, AI Factory waste-heat recovery for HVAC, building-envelope optimization.

§45D

New Markets Tax Credit (NMTC)

39% credit total over 7 years (5%/year years 1-3, 6%/year years 4-7) on Qualified Equity Investment (QEI) in a Community Development Entity (CDE).

Federal — Manufacturing & Program CreditsDetail +

Authority: 26 U.S.C. §45D · CDFI Fund NMTC Program
How the rate works: 39% credit total over 7 years (5%/year years 1-3, 6%/year years 4-7) on Qualified Equity Investment (QEI) in a Community Development Entity (CDE).
What qualifies: QEI in a CDE that lends/invests in a Qualified Active Low-Income Community Business (QALICB) located in a designated Low-Income Community census tract.
What has to be true: CDE allocation from CDFI Fund (annual competitive round). QALICB must maintain ≥40% of services/employees/property in LIC tract. 7-year compliance period.
How it becomes cash: Investor takes the credits — typically a tax-equity bank structures the QEI. Investor return: ~25-30% IRR after-tax.
Duration: 7-year credit window.
How SAVRN uses it: Imperial Valley and Texas Panhandle sites likely include LIC-designated census tracts. ~$200MM QEI per site eligible. Annual ~5-6%/yr credit flow during compliance period.

§1400Z

Opportunity Zone — Federal Capital Gain Benefit

Defer eligible capital gains invested into Qualified Opportunity Fund (QOF). 10-year hold: 100% exclusion on appreciation within the QOF.

Federal — Manufacturing & Program CreditsDetail +

Authority: 26 U.S.C. §1400Z · Treasury/IRS
How the rate works: Defer eligible capital gains invested into Qualified Opportunity Fund (QOF). 10-year hold: 100% exclusion on appreciation within the QOF.
What qualifies: Tangible business property used in a designated Opportunity Zone, substantially improved (doubled basis) within 30 months. Qualifying business with ≥70% OZ-located gross income.
What has to be true: QOF must hold ≥90% of assets in qualifying OZ property. 10-year hold to capture full exclusion. State conformity varies (California: non-conforming).
How it becomes cash: Investor-side benefit. SAVRN structures vehicles to accept rolled-over capital gain into project entity.
Duration: Investment window closes 2026-12-31 (current authorization).
How SAVRN uses it: Confirm whether each site's parcels sit within designated OZ census tracts. If yes, structure a QOF investor track alongside main investor track.

§48C

Qualifying Advanced Energy Project Credit

Up to 30% ITC on qualified investment with PWA (6% base without), allocated competitively by DOE/IRS.

Federal — Manufacturing & Program CreditsDetail +

Authority: 26 U.S.C. §48C
How the rate works: Up to 30% ITC on qualified investment with PWA (6% base without), allocated competitively by DOE/IRS.
What qualifies: Investment in facilities that manufacture or re-equip clean-energy components (fuel cells, electrolyzers, clean-energy equipment), process critical materials, or retrofit for industrial decarbonization.
What has to be true: DOE/IRS allocation required (concept paper → application → certification); PWA to reach 30%; placed-in-service milestones after certification.
How it becomes cash: §6417 direct pay (tax-exempt) and §6418 transferability available; otherwise general business credit.
Duration: One-time ITC on certified project investment; 5-year ITC recapture.
How SAVRN uses it: IntelliFlex modular fuel-cell + compute fabrication is advanced-energy manufacturing and fits §48C. NOTE: the full $10B allocation is exhausted (Rounds 1–2, ~250 projects); OBBBA added no funding — available only via recycled/forfeited allocation or Congressional reauthorization.

DOE Title 17

DOE Energy Dominance Financing Program — OBBBA New

Federal loan guarantee on infrastructure debt. Reduces effective cost of guaranteed debt by 1-2% versus market rate.

Federal — Financing ProgramsDetail +

Authority: OBBBA §41001 · DOE Loan Programs Office (LPO)
How the rate works: Federal loan guarantee on infrastructure debt. Reduces effective cost of guaranteed debt by 1-2% versus market rate.
What qualifies: Critical energy infrastructure projects: generation, storage, transmission, hydrogen, advanced fuels, advanced manufacturing of energy components.
What has to be true: DOE LPO application + technical, financial, legal underwriting. Davis-Bacon prevailing wage. Domestic content preference. Project-specific covenants.
How it becomes cash: Reduces interest expense over loan life. Captured as net interest savings vs. unguaranteed alternative.
Duration: Program new under OBBBA. Initial authorization through 2030.
How SAVRN uses it: AI Factory qualifies as critical energy infrastructure. Loan guarantee on debt-funded portion of infrastructure (e.g. transmission, switchyard, on-site generation). Estimated $50-100MM cash-flow savings per phase.

§168(k)

100% Bonus Depreciation — OBBBA Permanent

100% expensed in year of placement. Permanent under OBBBA July 4 2025 (TCJA phase-out reversed).

Federal — DepreciationDetail +

Authority: 26 U.S.C. §168(k)
How the rate works: 100% expensed in year of placement. Permanent under OBBBA July 4 2025 (TCJA phase-out reversed).
What qualifies: Qualifying property with recovery period ≤20 years. Excludes real property (39-yr life). Energy property reduced basis by §50(c): depreciable basis = capex − (50% × ITC credit amount).
What has to be true: §50(c) basis-reduction tracking for every ITC claimed. Form 4562 annually.
How it becomes cash: Year-of-placement deduction creates NOL. NOL carries forward, 80% income limit per year.
Duration: Permanent.
How SAVRN uses it: All IntelliFlex Block capex, DRUPS, thermal infrastructure, power electronics. Net basis ≈ capex − (50% × §48E credit). Cash tax shield ≈ net basis × 29.84% combined rate.

§6417

Direct Pay Election

Treats elected credits as a payment of federal income tax — refundable. IRS sends cash even if no tax liability.

Federal — Monetization MechanismsDetail +

Authority: 26 U.S.C. §6417
How the rate works: Treats elected credits as a payment of federal income tax — refundable. IRS sends cash even if no tax liability.
What qualifies: All applicable credits (§48, §48E, §45, §45Y, §45V, §45X, §45Z, §45U, §30C, §40, §40B, §45Q). For tax-exempt entities: unrestricted. For for-profits: limited to specific credits (§45V, §45X, §45Q, §30C, §6417(d)(1)(C)).
What has to be true: Election made on timely-filed return. Wage/apprenticeship and domestic-content rules apply to determine the credit amount being elected.
How it becomes cash: Cash from Treasury — typically 1-3 months after return filing. No discount.
Duration: Permanent for IRA credits.
How SAVRN uses it: For-profit SAVRN entity is generally NOT eligible for direct pay on §48E or §45Y — must use §6418 transferability instead. Eligible for direct pay on §45V (hydrogen) and §45X (manufacturing).

§6418

Transferability — Sale of Credits for Cash

Single transfer of an applicable credit to an unrelated taxpayer in exchange for cash. Sale proceeds tax-free to seller; buyer treats payment as nonde…

Federal — Monetization MechanismsDetail +

Authority: 26 U.S.C. §6418
How the rate works: Single transfer of an applicable credit to an unrelated taxpayer in exchange for cash. Sale proceeds tax-free to seller; buyer treats payment as nondeductible.
What qualifies: All IRA applicable credits (§48E, §45Y, §45V, §45X, §45Z, §45U, §30C, §45Q, §48C). Per-credit per-year transfer.
What has to be true: Pre-filing registration with IRS (Energy Credits Online Portal). Bona-fide transfer at arm's length. Buyer must hold passive-activity income to use credit (or be a corporate buyer with general use).
How it becomes cash: Cash at ~88-95% of face value. Pricing varies by credit type, year, market depth, indemnification structure.
Duration: Permanent for IRA credits.
How SAVRN uses it: Primary monetization path for §48E ITC and §45X credits. Tax-equity counterparts now compete against direct transfer buyers — typically results in tighter (better) pricing for SAVRN.

Tax Equity

Tax-Equity Partnership (Partnership Flip)

Partnership flip: tax-equity investor receives 99% of credits + depreciation until target after-tax IRR (typically 6-8%), then flips to 5% residual. S…

Federal — Monetization MechanismsDetail +

Authority: Subchapter K · Rev. Proc. 2007-65 (wind) / Rev. Proc. 2014-12 (solar)
How the rate works: Partnership flip: tax-equity investor receives 99% of credits + depreciation until target after-tax IRR (typically 6-8%), then flips to 5% residual. Sponsor (SAVRN) economics ~70-95% after flip.
What qualifies: Same applicable credits as transferability. Tax-equity adds depreciation allocation (§168(k)) and operating cashflow tied to project economics.
What has to be true: Bona-fide partnership for tax purposes — minimum 1% allocation to sponsor pre-flip. Operating-agreement compliance with IRS partnership-flip guidance. Annual K-1 reporting.
How it becomes cash: Cash investment up-front from tax-equity (typically 30-45% of project FMV). SAVRN retains operating control and most cash flow.
Duration: Pre-flip period 5-10 years typical.
How SAVRN uses it: Alternative to §6418 transfer. Best for assets with strong long-term cashflow + depreciation that exceeds credit value. Often preferred when investor wants both credits and depreciation shield.

Prevailing Wage

Davis-Bacon Prevailing Wage

Local prevailing wage rates (DOL Wage Determinations) for each labor classification. Required throughout construction and applicable operations.