§6418 — Transferable credits, settled on chain
§6418 allows an eligible credit to be transferred once, for cash, to an unrelated taxpayer.
What the Platform is, and is not
The Platform acts solely as a technology provider and administrative facility. It is not a principal, not a broker-dealer, not a tax adviser, and not a party to any tax-credit transfer. The transfer is between the seller and the buyer; the Platform operates the rail on which it is recorded and settled.
Four roles
Roles, not entities. Which party occupies which role is set per transaction.
- Platform
- Technology provider and administrative facility. Not a principal, broker-dealer, tax adviser, or party to the transfer.
- Seller
- The eligible taxpayer transferring the credit.
- Buyer
- The unrelated taxpayer acquiring it.
- Qualified verifier
- Independently attests the underlying production.
Cash release
Two paths, stated per contract. Under ESCROWED release, consideration is held and released against the agreed conditions. Under DIRECT release, consideration passes without an escrow leg. Which applies is a term of the transaction, not a property of the rail.