Transmission Tax Insurance for Clean Energy Projects - Alliant Insurance Services
Mar 19, 2026
James Chenoweth, Managing Director at Alliant and former tax lawyer who arranges tax insurance for complex energy and infrastructure deals. He explains how tax insurance shifts IRS credit risk to insurers. Short takes cover which technologies drive demand, pricing and placement in project finance, FEOC foreign‑ownership uncertainty, and why Texas leads the market.
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How Tax Insurance Actually Works
- Tax insurance transfers litigation and financial risk from a taxpayer to insurance carriers when legal advice says the tax position would likely win in court.
- Carriers review counsel advice and reimburse taxes, interest, and a gross-up if the insured loses, effectively making the taxpayer whole.
Who Uses Tax Insurance
- Demand for tax insurance is driven by financings where a lender, buyer, or tax equity investor depends on tax attributes to justify investment.
- Typical use cases include tax credit projects, bonus depreciation, and cost segregation in large deals.
Which Technologies Drive Demand
- Solar currently generates the most tax insurance demand by count, but growth will shift toward hydrogen, carbon capture, nuclear, and SAF projects.
- Batteries are already 'hot' now and will keep growing alongside large-scale clean fuels and CCUS.