T1 Energy Concludes FEOC Compliance Deals, Sells $160M Section 45X Credits
T1 finalized transactions with Trina Solar to maintain 2026 eligibility for Section 45X credits via capital raising, debt repayment, IP restructuring, and FEOC holdings limits. The company also executed a $160 million sale of Section 45X production tax credits at $0.91 per dollar to an investment grade buyer.
1. T1 Energy Secures FEOC Compliance Through Strategic Transactions
T1 Energy concluded a series of definitive agreements with Trina Solar, Evervolt Green Energy and other counterparties to ensure eligibility for the Section 45X tax credits in 2026. Over the past six months the company raised $200 million in equity and used $75 million of proceeds, along with common stock issuance, to reduce its Trina Solar–held debt below the 25% threshold mandated by the One Big Beautiful Bill Act. Amendments to its certificate of incorporation cap foreign entity equity at 25%, while a newly executed governance agreement strips Trina Solar of its former right to appoint covered officers. Intellectual property licensed from Trina Solar was transferred to Evervolt Green Energy, with T1 now holding non-FEOC licensing agreements after extensive due diligence. Supply-chain certifications and domestic sourcing agreements—from Hemlock Semiconductor polysilicon to Corning wafers and Nextpower steel frames—further strengthen the company’s material assistance compliance.
2. T1 Energy Completes $160 Million Sale of Section 45X Credits
In December 2025 T1 Energy executed its inaugural sale of Section 45X production tax credits, delivering $160 million of credits at $0.91 per dollar of credit generated to a top-tier U.S. financial institution. Third-party verification confirmed module production volumes through December, with a planned February 2026 true-up based on final output data. Citigroup Global Markets served as financial advisor on the transaction, which underscores T1’s ability to monetize federal incentives and supports ongoing investments in advanced manufacturing. The proceeds will bolster capacity at the fully ramped G1_Dallas facility and fund completion of the G2_Austin solar cell fabrication plant, positioning the company to scale domestic production in line with its strategic growth targets.