Dylan Fabbi, CPA
Founder
Dylan founded Fabbi after more than ten years at leading US accounting firms and investment banks. He leads the firm's credit transfer work, structuring each deal and making sure it's documented and filed correctly.
Tax credits, handled by CPAs.
Fabbi brokers and closes §6418 clean energy tax credit transfers. Buyers pay less than face value on their federal tax. Project owners turn credits into cash. We run the diligence, IRS registration, and filing in between, with more than $50 million in credits closed.
How do you want to use tax credits?
§6418 transferable credits
I want to buy credits
I owe federal income tax and want to pay less of it.
Start a purchase
§6418 transferable credits
I want to sell credits
I own a clean energy project and want cash for its credits.
Value my credits
Partner program
I advise clients
I'm a CPA, attorney, or advisor with clients who could benefit.
Become a partner
$50M+In tax credits closed
CPA-ledEvery deal reviewed by licensed CPAs
Individuals and companiesC corps, pass-through owners, and high earners
NJ and NY officesServing clients nationwide
See what buying credits could save you
Move the sliders to estimate a purchase.
Pay less than face value. Each dollar of credit is bought at a discount and applied in full against federal income tax.
Cash in, credit out. The seller doesn't count the payment as income, and the buyer doesn't deduct it.
Unused credits carry. Generally back three years and forward twenty-two.
Credit purchase estimate
§6418 transfer
You pay the seller$1,820,000
Net tax savings$180,000
Return on cash paid
9.9%
Credit appliedDollar for dollar
Illustration only. Pricing depends on deal size, credit type, seller strength, insurance, and timing.
How a transfer works
A typical transfer closes in about three months. Buyers who start early get better pricing and more time to plan estimated payments.
Size the deal
We model your federal tax, including passive-activity limits for individuals, and the right purchase amount. Sellers get a credit valuation.
Match and price
We pair buyers and sellers whose credit type, size, and timing fit, and negotiate price per credit dollar.
Sign the term sheet
Price, credit amount, payment timing, indemnities, guarantees, and insurance get locked.
Complete diligence
We review the project file and report findings before any money moves.
Register and close
The seller's IRS pre-filing registration is confirmed, and the purchase agreement is signed and paid in cash.
Claim the credit
Both sides file the transfer election. The buyer claims the credit on Form 3800 with their original return.
Built for everyone at the deal table
Pick your role to see the problems we solve for you.
What gets in the way
- Finding credits that are compliant and fully documented.
- Staff time spent verifying every purchase.
- Exposure if the IRS disallows or recaptures the credit.
How Fabbi handles it
- Buy with confidence. Every credit we bring you has been through CPA-led diligence first.
- Save your team's time. You get a clear summary of findings and open items, not a data room to sift through.
- Protect the purchase. Indemnities, guarantees, and insurance negotiated into the deal, and the filing done right.
What gets in the way
- Organizing hundreds of documents across dozens of categories.
- Round after round of buyer diligence requests.
- Bonus adders that aren't documented well enough to get paid for.
How Fabbi handles it
- Turn credits into cash. We value your credits and bring them to buyers with real tax capacity.
- A buyer-ready file. We build the package buyers, counsel, and insurers expect, and field their questions.
- Get paid for your adders. Wage and apprenticeship, domestic content, and energy community support documented so pricing reflects them.
What gets in the way
- Documents scattered across platforms and inboxes.
- Keeping momentum while thorough diligence runs.
- Tax and accounting questions that surface late in the deal.
How Fabbi handles it
- Close faster. We run the tax and accounting side of diligence alongside your legal work.
- More counterparties. Access to buyers and sellers across our client base.
- A clean finish. Registration, transfer elections, and Form 3800 handled.
What gets in the way
- Transferability rules are complex and keep changing.
- No easy source of vetted credits to recommend.
- Compliance and liability worries.
How Fabbi handles it
- Add a service. We handle sourcing, diligence, and the transaction while you keep the client relationship.
- Know who qualifies. We size each client's appetite, including passive-activity limits for individuals.
- Protect your reputation. Deals come with negotiated protections and insurance options.
Every step covered, first review to final filing
A transferred credit carries the project's risk. Select a phase to see what we do.
Get projects market-ready
New projects go through intake so their credits are ready to sell.
Guided intakeProject facts, costs, and timelines gathered up front.
Early checksGaps flagged before a buyer finds them.
Credit calculationEligible basis, credit rate, and bonus adders calculated and supported.
The right credits for the right buyers
We match inventory to what each buyer can actually use.
Buyer profilesCredit type, deal size, tax year, and risk tolerance on file.
MatchingProjects paired with buyers whose appetite and timing fit.
Proactive outreachYou hear from us when a fitting credit becomes available.
Everyone working from one plan
We coordinate buyer, seller, counsel, and insurers so terms get agreed quickly.
Term sheetPrice, payment timing, and credit amount agreed early.
One point of contactRequests and questions run through a single Fabbi lead.
Controlled accessEach party sees what's relevant to their role.
Diligence that holds up
We test the items most likely to reduce or disallow a credit.
TimingPlaced-in-service evidence and the July 4, 2026 wind and solar construction deadline.
Credit rateWage and apprenticeship records supporting 30% over the 6% base.
Adders and sourcingDomestic content, energy community status, and prohibited foreign entity rules.
Close and file on time
We track every IRS step until the credit is claimed.
Pre-filing registrationRegistration numbers and dates tracked for every property.
DeadlinesReturns extended when a deal closes after the filing date.
Elections and Form 3800Prepared for both parties and claimed correctly.
Protection for the life of the credit
We coordinate tax credit insurance and keep coverage in view through recapture.
Policy coordinationQuotes, underwriting, and binding managed alongside the deal.
Coverage reviewLimits, exclusions, and retention checked against the credit.
Recapture periodOwnership and covenants monitored for five years.
Tax credits for individuals
High earners, trusts, and pass-through owners can buy transferable credits too. What matters is the kind of income the credit can offset.
Passive income is the target
For most individuals, purchased credits are passive and generally offset tax on passive income, such as rental income or K-1 income from businesses you don't actively run.
Buy the right amount
We model your passive income and tax first so you don't buy more credit than you can use this year.
Your CPA files it
We prepare the transfer statement and credit forms with your return and adjust estimated payments.
Credit structures compared
A transfer is one of several ways to turn clean energy credits into value.
| Structure | How it works | Who it fits | Trade-offs |
|---|---|---|---|
| Transfer (§6418) | The owner sells credits to an unrelated taxpayer for cash. The buyer claims them. | Corporations and individuals with federal tax; developers who want cash. | Simpler and faster than tax equity. No basis step-up. One transfer per credit. |
| Tax equity partnership | An investor joins the project partnership and receives most credits and depreciation. | Large institutional investors. | Captures depreciation and a possible step-up, but costly and complex. |
| Hybrid (T-flip) | A tax equity partnership that also sells some credits by transfer. | Large projects seeking depreciation value and liquidity. | Most flexible, most complex. |
| Direct pay (§6417) | The IRS pays the credit value to the owner as a refund. | Tax-exempts, governments, and a few specific credits for others. | Not available to most for-profit owners. |
Transferable credits include the investment and production credits (§48, §48E, §45, §45Y), advanced manufacturing (§45X), carbon capture (§45Q), and others. Eligibility depends on project facts and current law.
Meet the team
A small, senior team. You work directly with the people running your deal.
Rebecca Gold
Lead Intake and Advisor
Rebecca is the first point of contact for buyers, project owners, and advisors. She reviews each inquiry, gathers what's needed to size a deal, and guides clients on next steps.
Common questions
Don't see yours? Email info@fabbi.co.
What discount should I expect?
It depends on deal size, credit type, seller strength, and timing. Larger deals from investment-grade sellers trade closer to face value; smaller deals usually carry a wider discount. We'll show you current pricing for your size.
Can individuals buy tax credits?
Yes. Individuals, trusts, and pass-through owners can buy. Credits are generally passive for individuals, so they typically offset tax on passive income. We model this before you commit.
Can I buy credits for a tax year that's already ended?
Often, yes. The credit must be claimed on your original return, so if the deal closes after your filing date, your return must be on extension and not yet filed.
Can I lower my estimated payments once I've agreed to buy?
Generally you can factor in a credit you've contracted to buy. We coordinate timing so you don't face underpayment penalties.
What happens if the IRS reduces the credit?
The buyer bears the adjustment, and an excessive transfer can carry a 20% penalty unless reasonable cause applies. That's why indemnities, guarantees, and insurance are built into every deal we broker.
Are sale proceeds taxable to the seller?
No. Cash received for a transferred credit is excluded from the seller's gross income, and the buyer can't deduct the payment.
Who can't participate?
Related parties can't transfer credits to each other, and projects owned by or relying on material assistance from prohibited foreign entities can lose eligibility for the clean electricity credits.
Is the wind and solar construction deadline final?
Treasury's beginning-of-construction guidance for wind and solar has been challenged in court this year. We check the current status on every deal and price that risk into the terms.
Let's get your credits working
Send a few details and Rebecca Gold, our lead intake advisor, will reach out within one business day.
- We review what you're trying to accomplish.
- Rebecca calls to talk through options and pricing.
- You get a clear plan for buying or selling.
Morristown55 Madison Ave, Suite 400
Morristown, NJ
Morristown, NJ
New York800 3rd Ave
New York, NY
New York, NY
Phone(929) 265-1681
Emailinfo@fabbi.co
Tax credits, handled by CPAs.
More than $50 million in credits closed. Let's add yours.