Direct placement of transferable tax credits.
Bjorklund Consulting places transferable federal and state tax credits directly between the companies that earn them and the taxpayers that buy them. The supply we bring to buyers is off-market: sourced directly from the seller, not listed on marketplaces or circulated through broker networks.
We contract with either the seller or the buyer and work with counsel on each side through closing. We typically place tranches of $15 million and above.
What we do
Placement
We bring a seller a buyer, or a buyer a seller. Sellers are quoted a firm net price before diligence begins, and our compensation is not deducted from it. Transaction documents are negotiated by each party's counsel; we set the commercial terms, keep both sides' advisers on the same timetable, and see the transaction through to closing.
Seller diligence preparation
Before a buyer's counsel sees the package, we review it against what that counsel will ask for: registration numbers, production or cost-basis support, prevailing wage and apprenticeship records, beginning-of-construction and placed-in-service support for investment credits, and the prohibited-foreign-entity and material-assistance support that §45X, §45Y and §48E credits now require. The indemnity is sized to the seller: a corporate indemnity, a parent guaranty, or a tax credit insurance policy placed through the seller's insurance broker.
Buy-side sourcing
For taxpayers with capacity to fill, we source off-market supply matched to credit type, vintage, size and the indemnity standard the buyer requires. Multi-year programs commit capacity now and take delivery as credits are earned.
Engagement
We are engaged in writing by either the seller or the buyer, and our compensation is set out in that engagement. Counterparty identities are disclosed under NDA.
Who we work with
Sellers
Producers, manufacturers and project owners earning federal or state credits: fuel producers, component and critical-mineral manufacturers, owners of generating, storage and nuclear assets, and developers holding certificated state credits.
Buyers
Corporate taxpayers, banks, insurers and family offices, and the tax counsel and advisers acting for them.
Intermediaries
Brokers, bankers, accountants and advisers who hold a direct relationship with a buyer or a seller and want a placement run to that party's standard.
Counsel
We work alongside the buyer's and seller's law firms, which settle the transfer agreement, indemnity and election.
Ephraim Olson
Ephraim Olson is the founder and principal of Bjorklund Consulting. He is a tax attorney, a graduate of Harvard Law School, and admitted to practice before the United States Tax Court. He practices law separately, through Olson & Partners Law, in federal energy tax: the §48 and §48E investment credits, the production credits, §6418 transfers, and opportunity zone structuring, including the opinion letters on which investors and insurers rely.
Since 2024 he has advised on more than $250 million of tax credit transfer transactions, on the sell side, the buy side, and as the intermediary between the two, across investment and production credits and with counterparties ranging from private developers to corporate purchasers. That work is the basis for Bjorklund Consulting: the pricing, the diligence standard and the closing mechanics are the same at every size, and a transfer runs best when the person in the middle has sat on each side of it.
Bjorklund is a bespoke practice. Every engagement is led by the principal, from first call to closing.
Credits we place
Every credit transferable under §6418, and state credits that may be sold or certificated for transfer. Federal credits transfer once, for cash, before the seller files for the year the credit was earned; the cash is not income to the seller and not deductible by the buyer. A reference page describes each credit, who earns it, its recapture period, and what a buyer's counsel will ask for.
Production credits
Investment credits
State
Contact
Write with the credit type, vintage and approximate amount, or the capacity you want to fill. Replies come from the principal.
- [email protected]
- Phone
- +1 (213) 500-9105
- Address
- Bjorklund LLC
1607 Avenida Ponce de León, Ste. GM6 #773
San Juan, Puerto Rico 00909