T1 Energy Inc. has concluded a series of targeted transactions with Trina Solar and other counterparties to preserve eligibility for 2026’s Section 45X tax credits under the One Big Beautiful Bill Act. Over the past several months, the company amended its certificate of incorporation to cap foreign entity equity ownership below the 25% threshold, raised new capital in late 2025 and used a portion of those proceeds (alongside common stock) to pay down Trina Solar–held debt below the compliance limit. T1 also removed Trina Solar’s right to appoint covered officers, transitioned its intellectual property license from a related party to Evervolt Green Energy (after confirming Evervolt’s non-FEOC status), and conducted supply-chain diligence to source non-FEOC solar cells for 2026 production. These measures, combined with planned domestic sourcing of polysilicon, wafers, cells and steel frames, position T1 to meet effective-control and material-assistance provisions and secure up to five years of production tax credits for its high-domestic-content modules.

In December 2025 T1 executed its inaugural sale of $160 million in Section 45X production tax credits to an investment-grade buyer at a substantiated rate of $0.91 per credit dollar. The transaction, which covers credits accrued and third-party verified through December, was structured with a scheduled true-up in February 2026 upon confirmation of month-end module production. Citigroup Global Markets served as financial advisor on the deal. According to CFO Evan Calio, this landmark sale demonstrates T1’s ability to convert tax incentives into near-term cash flows, strengthening the balance sheet and supporting ongoing investments at the fully ramped G1 Dallas facility and the under-construction G2 Austin solar cell fabrication plant.