ITC Start of Work Certificates: Perspectives for Risk Mitigation

Investment Tax Credit (ITC) compliance hinges on meeting IRS Start of Work (SOW) requirements, which can significantly impact project economics and tax equity financing. This panel brings together investors, tax attorneys, and other technical experts to unpack the complexities of start-of-work (SOW) certification and verification. We will explore safe harbor strategies through physical work and continuous construction requirements. Panelists will discuss financial implications such as tax equity structures and deal certainty as well as legal issues such as audit risks, contractual language, and foreign force majeure considerations for global developers. Attendees will leave with an understanding of how to align engineering diligence, financial structuring, and legal compliance to protect ITC value and accelerate project execution.