Value Creation in the Transferable Tax Market

Title: Value Creation in the Transferable Tax Market
Speakers: Craig Kline and Adam Kobos

Craig Kline (00:08):
Adam, great to be here with you today. We finally have a transferable tax credit. What are your thoughts?

Adam Kobos (00:15):
It’s been a long time in the making. There have been discussions about this for years, but it is revolutionary. Compared to what we had before, credits were non-transferrable, non-refundable, meaning only the taxpayer who was the owner could use them and we’d had to use these really complicated leasing and partnership transactions to monetize the tax benefits. Now we’ve got this new portfolio of options with direct pay and with transferable credits and transferable credits in particular I think offers some really exciting opportunities. What are you thinking about in terms of what this might offer our clients and people in the industry?

Craig Kline (00:54):
Well, when you think about it, the needs for renewable energy to facilitate the energy transition are tremendous. And historically, we’ve had just a few institutional bank investors that were able to provide their own tax capacity in order to facilitate sponsors’ ability to raise capital and invest in renewables. So federal government, I think, wisely said the market expansion is gonna be so tremendous. And the limitation on tax credit is the tax capacity of a few institutional investors that understand the renewable energy market in such a way that they can put their money to work, and realize a return on investment. But they have to really understand the renewable energy market. A transferable tax credit allows any corporate investor, and we can talk about later whether consumers and mom and pops would have the ability to take a transferable tax credit.

But what it does is it allows anybody with a tax bill to decide instead of paying their tax bill 100 cents on the dollar, dollar for dollar, that they’re gonna help facilitate renewable energy by buying a tax credit, for either the generation of renewable energy or investment in renewable energy, buy that tax credit and reduce their tax burden while also facilitating investment in renewable energy. And that’s something we haven’t seen.

Adam Kobos (02:39):
Craig, I think what’s interesting about this transferability mechanism as compared to the Section 1603 grant program is the government in a sense is out of the picture, right? Ultimately, the buyer of the credit is gonna report it on their tax return, but the government in itself is not partying with the money the way it did in the Section 1603 grant program. It’s just a refund that shows up on the buyer’s tax return. They’re letting the market figure out how to monetize the tax credit and leaving the government maybe out of it a little bit.

Craig Kline (03:09):
Right. Right. There’s not an application program, or at least at this point, we don’t expect there to be sort of an application program going through treasury. In this case, you’re just dealing as a taxpayer with the IRS on your return.

Adam Kobos (03:23):
Now, there is an interesting provision in the legislation that says, as a condition of granting the transfer, the IRS has the ability to ask for further information. So theoretically, we could end up with something like the Section 1603 grant program, though I think there’s gonna be a strong push from industry to say, “Let’s keep this lean and mean and not hinder or slow down the process of monetizing these tax credits.” But that feature, I think we’re finding is, the possibility of that IRS review and the uncertainties about what it might involve are slowing down the market a little bit, right? ‘Cause we’re not seeing these deals being executed yet, or maybe we’re just at the beginning of starting…

Craig Kline (04:06):
Well, there’s so many questions, right? There’s just so many questions. The expectation based on how the law is written is that the party that is taking the tax credit, in this case, as we’re talking about transferability, that’s the transferee, right? So the transferee buys the tax credit presumably for some discount on the benefit of the credit. So for instance, if you have a $100 tax liability and you buy a tax credit for renewable energy for $100, there’s really no benefit here.

Adam Kobos (04:40):
Yeah, what’s the point?

Craig Kline (04:41):
What’s the point? So you need to discount the tax credit. If I’m a transferee, if I’m buying the tax credit, I wanna facilitate renewable energy, but I’m obviously not gonna do this if there’s not some benefit to me. So that buyer’s gonna buy it for 90 cents on the dollar, 95 cents on the dollar.

Adam Kobos (04:57):
What do you think the price is gonna be?

Craig Kline (04:59):
I think it’s gonna depend on the risk you’re asking me to take. So traditional tax equity is very sophisticated. So traditional tax equity comes to the market and says, “I wanna invest in this win project.” They diligence the win project as well as anybody that was just a purchaser in an M&A deal buying the project. So they diligence that project, they know that project, they’re doing the commercial diligence, they’re doing their tax diligence, because they’re gonna take in a traditional deal, they’re gonna take the tax benefits. And many of the sort of legal risks associated with tax benefits they’re going to be taking, they really need to understand and diligence that project. If you’re now in this new regime, we have post-IRA, there’s a transferable tax market that’s developed. I’m buying presumably the tax credit for some level of a discount.

The price I’m gonna pay for it, you would think this has to have some rational relationship with the risk that I’m taking. And so if I’m a corporate investor that doesn’t know anything about renewable energy but wants to participate in the market, well, I’m gonna come in, but I also have a treasury to report to, my own treasury, my corporate treasury to report to, and I’m gonna show that I’m gonna do this and generate some revenue, some benefit to the company. But the price I’m willing to pay and the risk I’m willing to take are gonna be correlated. So –

Adam Kobos (06:21):
Yeah. More risk. I mean, if you pay $90 million for a tax credit and it goes away, you’re in a world of hurt. So I think there’s zero tolerance for risk here. Right. I’m with you, right? So, well, what does that mean in the context of agreements? I think we’re gonna have very airtight indemnities. Right?

Craig Kline (06:40):
I think that’s right. I think in a traditional tax equity deal, the tax equity investor, the taxpayer, the one that’s taking the tax benefits, is willing to take some risk because they did diligence the deal. They are partners in a partnership.

Adam Kobos (06:54):
The tax lawyers are gonna make them take risks.

Craig Kline (06:56):
And the tax lawyers, like you, write tax opinions to demonstrate that the tax benefits are justified. But if you’re trying to create, and which we are, right, create a more robust tax credit market, buyers can’t take the risk. They’re not gonna have the level of sophistication, for the most part, to really truly underwrite both commercial and tax risk. So there needs to be some assurance that the tax… So do you think that sponsors developing solar and wind and other renewable projects that are eligible for these tax credits, these transferable tax credits, do you think they’re going to be themselves willing to fully backstop the risk of the tax credit being eligible?

Adam Kobos (07:39):
I think that’s a great question. I think the market’s developing. We’re gonna see this develop over time. But I do think given the push for higher prices, which means lower risk for the buyer, it’s probably in the end gonna be in the sponsor’s interest to do whatever it takes to make the investor comfortable here. Right. And that means very, very tight indemnities. And then potentially some credit support. Right. So if the sponsor is a special purpose entity with no assets other than the project, I don’t know that the investor’s gonna find that structure, that purchase particularly attractive. Right. So maybe guarantees.

Craig Kline (08:17):
Right. Maybe there’s a parent company that has a more robust balance sheet that can provide a guarantee.

Adam Kobos (08:24):
And then maybe tax insurance, right? So we’ve seen in the tax equity world over the past three, four years, tax insurance become a much bigger feature of our tax equity transactions. Insurers are entering into the market. Prices have come down. And having talked to a number of tax insurance brokers and providers, they’re very, very excited about this transferability market. So I think I’d expect there to be a significant part for tax insurance to play.

Craig Kline (08:52):
Right. And I think if you can create, and we will, and we’ll see this, a real robust insurance policy that assures the buyer of the tax credit that the tax credit’s going to be respected. Yeah. I think that will really facilitate the tax transfer market.

Adam Kobos (09:09):
Yeah. And I agree. And I think we’re seeing those policies now in the tax equity market, covering a broader range of risks, including not just the risks on day one, but for credits like the ITC that are subject to recapture. Covering risks going forward for a number of years, recapture risks – Right. Other things that can go wrong with the project. Right. And that then is a very powerful risk mitigation tool. And I think that’s gonna be a key feature of these policies.

Craig Kline (09:35):
Right. I think it’s important to note that the tax transferee, the one putting the tax credit on their return, is the one that’s taking the risk that they’re eligible for the tax credit and taking the risk that the project stays in service. If they’re doing an ITC deal, stays in service long enough so they’re not subject to recapture, which is just basically the government saying, “Give me my money back. Your solar deal that we thought we were financing, for example, is no longer in service.” Adam, folks lately have been talking about putting the risk of the eligibility of the tax credit on the seller of the tax credit. What do you think about that?

Adam Kobos (10:12):
We’ve heard this discussed or raised by a couple of people, and I’ll admit that the section of the code on point is not really a model of clarity. But it says generally that the buyer of the tax credit is treated as the taxpayer for purposes of the code. And that would tend to suggest that the buyer is the person who wears the recapture risk for this purpose. But if the IRS wanted to facilitate the development of the market, there may be a policy reason for pushing this risk back to the seller.

And the issue here is the buyer just doesn’t have any control over the project. It’s the seller who’s gonna be operating the project and managing it, deciding what to do if the project isn’t generating enough revenues to cover expenses, are they gonna keep it going? And for that reason, it might make some sense to keep that recapture risk on the seller. Again, from a policy perspective, allowing a cleaner purchase of the credit from the buyer.

Craig Kline (11:10):
Right. If I’m the buyer of a tax credit, boy, I would love not to have to take any risk associated with it. That’s right. And for all the risk to be stranded with the seller. Yeah. But if I’m thinking about it from an overall policy perspective, and we’ve been doing this for long enough to know that there can be fraud, right? There is an opportunity for abuse of any system. And I personally think that if you’re going to have a transferable tax market by putting the burden on the transferee and make sure that the transferee knows what they’re getting, does the diligence buys insurance if they feel they need to buy insurance, get credit support if they need to get credit support. What would worry me about a transfer holding the risk is if there’s any fraud in the system, that transferor might not be there to go after on day two.

Right. We’re so used to a traditional tax equity transaction with robust diligence. As a tax lawyer representing the transferee in a tax credit deal, how much diligence do you need to do to feel comfortable as a transferee? Granted, this is in today’s regime, we expect this is the entity that’s gonna take the tax benefits. Even in a deal where you wrap the tax benefits with a good credit. How much diligence do you think is an appropriate amount of diligence to do as the transferee?

Adam Kobos (12:34):
Yeah, that’s a really good question. I think it’s gonna depend a little bit on who the buyer is. And I think we see maybe three classes of potential buyers. Banks who are otherwise participating in the tax equity market being one of them. Corporate investors with sophisticated tax departments. And then maybe a more retail market if the rules allow individuals to invest or maybe smaller corporations. And I think depending on the nature of the buyer, they’re gonna have different concerns. Right. So I think our tax equity investors are going to, at least at the beginning, are still gonna want some diligence. And maybe even a tax opinion. But certainly a certain amount of diligence that lets them get comfortable that that credit was really realized. To the point you’ve made before, that there’s a real project there, right? That it’s not just imaginary. But also that the other tax characteristics of the project allow for a credit.

Craig Kline (13:29):
Right. I fully expect that a lot of the buyers of these tax credits are gonna still be those large institutional investors. Yeah. They may not be the institutional banks that are currently participating in the market, but these are large institutional investors. They’re gonna be writing big checks and they have shareholders to report to. So they’re not gonna be comfortable just signing a check without doing some level of diligence.

Adam Kobos (13:51):
Yeah. Now, as the market develops, and maybe for different classes of investors, I think some investors are gonna look at this as kind of a treasury function. A way to pay their taxes more cheaply. And maybe there are robust marketplaces where you can look up the pricing on the internet and execute a trade on a particular credit. And at that point, maybe we’re not seeing robust diligence. But I do think in the beginning stages, as people get used to this idea, I think we’re gonna be seeing some diligence.

Craig Kline (14:25):
Right. So we represent a lot of sponsors. We represent a lot of banks. What we’ve been hearing recently from a lot of our bank clients is that when they think about lending into renewable energy deals, maybe what they should think about is not just providing a loan product, but also providing the ability to be transferee in a tax credit deal. And to your earlier point, when you think about diligence, they’re already doing the diligence on the project as a lender in the facility. So why not layer on top of that the ability to take the tax credit as well? The diligence done. And in fact, you may be able to do deals where the lien on the project for the benefit of the loan facility could also be available for securing whatever indemnities the sponsor’s backstopping for the tax credit. So there may be a very interesting product and we’re talking to some folks about that right now, an interesting product that is both a debt and a tax credit product.

Adam Kobos (15:25):
Will there be traditional tax equity after direct pay and transferability?

Craig Kline (15:31):
Of course there will. There will be traditional tax equity with transferability as well. I fully expect that the market for tax equity is really not materially gonna change. If anything, it’s gonna continue to grow, right? When the CBO scored how much the transferability was gonna cost in the legislation, they assumed a certain level of growth. I think they might’ve underestimated it because I think what the transferability market’s gonna allow is a whole class of sponsors that hadn’t prior been able to access traditional tax equity to now be able to access it through the transfer market. But large deals, the traditional deals that you and I work on every day, those deals are still going to be done, I think, by traditional tax equity.

Adam Kobos (16:20):
Yeah. The word is, and people have looked at this extensively, obviously the math here is extremely complicated and it depends on the projects. But I think there’s been general agreement out there in the market that the benefits of tax equity mean tax equity transactions are still a more efficient use from the sponsor’s perspective. And there are a few reasons for that, right? The transferability deals require a discount on the credit. So if you generated a dollar of tax credit, you’re not getting a dollar from your buyer. You’re getting, the prices yet to be determined, but 90 cents, 92 cents. Right. In a tax equity deal, you can monetize depreciation. Right. That’s another benefit of the tax equity transaction. And then yet another benefit is the ability to step up the basis in investment tax credit deals. The tax equity structure lends itself more easily to stepping up the basis, which allows you to recognize a higher dollar value on the project.

Craig Kline (17:19):
Right. And there’s certainty, right? If you’re doing a traditional tax equity deal, a PTC deal on wind or now on solar, whatever. If you’re doing a traditional tax equity deal and you’re a sponsor, the benefit of traditional tax equity is that you have certainty, right? You close your deal. You get day one proceeds if you’re doing a PTC deal. Obviously, if you’re doing an ITC deal when you do your final funding, you’re getting all the proceeds. But when you do a PTC deal, you’re getting proceeds on day one and you’re getting a commitment for your tax equity investor partner to buy your PTCs effectively over the remaining life of the PTCs. So over a 10-year period. If you’re playing in a new transferability tax market, the question is, to what extent are folks that don’t really understand the project willing to commit to 10 years of taking PTC? And these are folks that don’t know what their tax appetite’s gonna be years down the road.

Adam Kobos (18:15):
Yeah. I think those long-term commitments in the transferability market are much more complicated, much trickier.

And we’d expect to see discounts, right? From the investor side. They’re setting aside tax capacity over a long period of time. Right. As a result, they may want a further discount on the credit for allocating that. Right. So I agree that the tax equity transactions are sort of built in a way to allow for this kind of long-term monetization of the credits. And maybe down the road as the transfer market develops – Right. When you enter into a deal, you’ll have assurance that you’ll be able to sell your credits down the road for a good price, but we’re certainly not there yet.

Craig Kline (18:56):
Right. And inertia is a really powerful thing. The market is the market. The market that developed, developed around traditional tax equity investors. So banks coming in, others as well, but banks coming in and providing their tax appetite and using either sale leaseback structures, partnership flip structures, using, in some cases, inverted lease structures. There’s already a developed market and the inertia of that is going to carry forward, I think, for a long time.

Adam Kobos (19:23):
So Craig, say I’m a sponsor and I wanna monetize 10 years of PTCs. What does a commitment from an investor look like? What is an investor gonna be willing to sign up to? And what kind of price are they gonna offer me?

Craig Kline (19:37):
That’s a great question, Adam, right? Because if you think about it from the buyer of the tax credit’s point of view, and let’s say I’m a buyer who is not really sophisticated, hasn’t done a ton of solar and wind before and is just thinking about wanting one to help facilitate the energy transition by buying PTCs, also wanting to lower its tax bill as well. When they’re thinking about how are they going to manage their tax bill, how many years forward can they think about that, right? Can they know seven, eight, nine, 10 years out what their tax appetite’s going to be? Maybe. Maybe some of the more sophisticated ones really do have that ability, but maybe not. So I would think that the cost to a seller is going to be directly proportional or inverse proportional to the commitment that the buyer’s going to make.

So presumably if the buyer’s going to make a commitment for 10 years, there has to be some discount associated with that commitment.

Adam Kobos (20:44):
Yeah, it looks a little bit like a loan commitment fee, right? Setting aside, in this case, tax capacity. Or a loan, it would be the ability to lend.

Craig Kline (20:52):
Right. Timing’s a really interesting thing. So at what point do you start valuing the transfer tax credit for purposes of pricing the tax credit? Is it when the project, let’s do an ITC deal, project placed in service? Or is it some other point in time during the tax year?

Adam Kobos (21:15):
So we’ve been racking our brains over that, talking about it internally. And I think the answer is there’s no perfect answer. If, let’s say I know now that I’m gonna invest in a project that’s going in service this year. I could start reducing my estimated tax payments now, knowing that I’m gonna buy this credit, and apply it to my tax return for 2023, which I’ll file in 2024. So there’s an argument that maybe that tax credit is producing a benefit for me now, even though the project hasn’t been placed in service, even though I can’t use it on my tax return until next year and even though I can’t use it on my tax return until I know that the seller has made the election that allows me to use it. So there might be arguments for saying that the economic benefit is re-downing to me now because I can use it.

Craig Kline (22:07):
So what do you think the answer is?

Adam Kobos (22:08):
Well, I’m not sure people are gonna be willing to go there. The convention maybe will develop more like maybe it lands when the project is placed in service. Or maybe it lands when my tax return is due next year.

In the end, I think these distinctions will become driven more by when the parties transact in a liquid market. Right now, I think the parties are gonna negotiate some of these timing provisions and then let numbers fall out where they may.

Craig Kline (22:38):
Certainly for larger tax equity deals that are going to use transferability as part of their overall tax structuring. I think for those large deals, they’re going to be negotiated deals, right? They’re not going to be through some liquid market created by some broker. It’s going to be a bilateral arrangement.

Adam Kobos (23:00):
I agree.

Craig Kline (23:01):
So in those bilateral arrangements, if I’m the buyer of the tax credit, I’m managing my tax position. So I need to have some certainty that if I’m putting my commitment behind buying the tax credit, you as the seller of the tax credit have to put some commitment behind actually offering up that tax credit.

Adam Kobos (23:23):
So what does that look like? Does that mean as a buyer, will you be doing diligence on the ability of the project to produce those tax credits? Or do you think in lieu of diligence, is it gonna be some sort of fee that gets paid or discount that gets paid to get you there?

Craig Kline (23:38):
That’s a great question. I think there needs to be a fee. There needs to be some certainty. It’s really just an unused commitment fee that would run to the benefit of the buyer if the project doesn’t produce. But in a liquid market, maybe it doesn’t matter where the tax credits come from. In a purely liquid market, maybe it doesn’t matter. Certainly a purely liquid market for PTCs, it’s kind of like a rec market. If I don’t deliver rec from project A, I’ll deliver it from project B. Does it matter? If you’re interested in just PTCs, I don’t know that it should necessarily matter where those PTCs come from.

Adam Kobos (24:17):
Do you think we’re gonna see liquid markets or public markets or markets that buyers and sellers can access? What does this look like over time?

Craig Kline (24:29):
Well, as you know, there’s plenty of developed markets for state tax credits. And you know that there are brokers looking at this right now and trying to develop a liquid tax credit market. So I certainly think that there’ll be a tax credit market for folks to come in and participate that don’t necessarily have the individual relationships to strike deals, but would wanna go through a broker.

Adam Kobos (24:54):

Yeah. The way the credit is structured, there can only be one buyer. And so this will impact the sort of markets that we might see. We’re not gonna have some sort of exchange where there can be active trading. But there will be… I think we fully expect that there will be marketplaces, maybe in different places sponsored by particular brokers that will arrange transactions between buyer and sellers and get you to something like the same place.

Craig Kline (25:20):
Right. And I think that’s a really good point you make about there only being an opportunity for one transaction, one seller, one buyer of a tax credit. I think that really lowers the risk of fraud because you’re not in a sort of derivative, this is a tax credit that’s now been traded 10 times down from… And you don’t even know where it started from. In every instance, you ought to know, even when going through a broker, you ought to easily be able to figure out where that tax credit was generated. But interestingly, doesn’t the IRA allow you to break up your tax credit into as many pieces as you’d like and sell to multiple parties?

Adam Kobos (25:56):
Multiple buyers. That’s correct. That’s correct. So you have the ability as a seller of a credit to find multiple buyers. If you have a huge project generating lots of tax credits, you can tranche it up and sell it to multiple buyers.

Craig Kline (26:08):
Right. And if you’re a sponsor who has this terrific solar project that you’re doing with PTCs or a wind project with PTCs, you have the ability to manage when and to whom you sell those PTCs. Presumably you could sell just two years of PTCs and then see where the market lands in year three and sell year three’s PTCs later.

Adam Kobos (26:31):
That’s right. That’s right. There’s a lot of flexibility in terms of how you break this up.

Craig Kline (26:34):
Right. One of the downsides of that is you’re not monetizing 10 years of PTCs on day one. And when you’re thinking of the capital stack, you wanna get as much money as you can on day one.

Adam Kobos (26:45):
Right. So for a sponsor who’s gonna rely on that forthcoming tax credit market, that’s a tough position to be in right now. So tough to build a project if you don’t know how you’re gonna monetize your tax credits in the future.

So Craig, in traditional tax equity, we have construction loans and tax equity bridge loans. Are we gonna see something like that for transferable tax credits?

Craig Kline (27:11):
Oh, most certainly. Whether you’re dealing with a traditional tax equity transaction or in this new market of a transferable tax credit, there’s still gonna be the need for debt during construction. And the timing, as you pointed out earlier, the timing of when that tax benefit comes may not be immediate. So it may be later on. And certainly for a PTC deal, that timing would be over 10 years. So I fully expect that there’ll be a construction to back leverage market developed as well. And I think if you’re a construction lender that’s providing construction to back leverage, component of that is a tax equity bridge loan. Whether you’re doing a traditional tax equity deal or you’re doing a transferable deal, you’re gonna wanna understand how firm the commitment is for the tax credit buyer to buy that tax credit, whether through, again, a traditional deal or a tax credit deal.

So currently, if you’re the debt, you wanna look at and understand that level of commitment. You’re gonna review the tax equity documents and understand that level of commitment. And you’re not gonna put your money in on day one until you’re reasonably confident that that commitment is firm and you’re secure that the tax benefits essentially are going to be monetized to support your debt. So I think for sure there’s gonna be that level of diligence required to understand how firm that commitment is.

Adam Kobos (28:36):

Yeah. And I think the question is, do we have the IRS guidance that we need right now? And I think the answer is probably no. Need a little more IRS guidance before buyers of tax credits are going to be willing to give firm commitments. And that means maybe then it’ll be a little while before we see the sort of bridge loan concept. But I think we expect to see it.

Craig Kline (28:59):
I do, we do expect to see it. I think the inertia right now is in favor of traditional tax equity until we get guidance. And once we have guidance, there will be structures that come around where you’ll have firm commitments that tax equity investors that are buying transferable tax credits feel confident enough to make a firm commitment. Right now, if they give a firm commitment, it’s gonna have all sorts of conditions on the guidance. So how firm is that? Yeah. And how willing is a lender going to be to lend into that? I don’t think we’re going to see an insurance product that’s going to ensure either change of law or unknown guidance.

Adam Kobos (29:35):
Yeah. So I think a theme that we’re coming back to in this discussion is we expect this market to develop. We expect structures to be created to take advantage of it, but we need some IRS guidance on that process of transferability before the log jam’s gonna be broken.

Craig Kline (29:51):
Agreed. So Adam, as someone that pays taxes and is interested in supporting the energy transition, I would like personally to be able to invest in renewable energy through a transferable tax credit. Can I personally take a transferable tax credit? Can I go out and buy for 90 cents or 95 cents on the dollar, PTC tax credit for a solar project that’s being built here in Arizona?

Adam Kobos (30:16):
That’s such a great question. And look, everybody in our industry wants to do this. We’re waiting for guidance, unfortunately. There are arguments that say you ought to be able to do it. But the key question is whether certain limitations on credits, the passive activity rules and the at-risk rules, whether those might apply to individuals buying credits. There is a good statutory argument that the passive activity and at-risk rules shouldn’t apply, but there is concern that the IRS is gonna find a way to make those rules apply here.

Craig Kline (30:49):
Well, I would argue that the policy should allow any retail investor that pays taxes to invest in, just like a corporation, any corporation today, any US tax-paying corporation can get the benefit of a transferable tax credit. I think there’s a terrific policy argument for any retail, any individual, you or me or anyone, should have the ability to invest in renewable energy through a transferable tax credit.

Adam Kobos (31:19):
I agree with you. I agree with you. The passive activity and at-risk rules were developed decades ago to shut down retail tax shelters. That’s not what we’re talking about here. We’re talking about promoting renewable energy.

Craig Kline (31:30):
Think about the amount of appetite there is in the country to invest in renewable energy and imagine being able to do that and reduce your tax bill at the same time. I think a transferable tax market that benefits a retail individual like you and me or anyone else would be a game changer.

Adam Kobos (31:47):
I agree. I agree. Let’s hope the IRS can get there.

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