A federal district court just struck down an IRS rule that had been closing the door on a pretty compelling tax savings opportunity available to your clients today, the Section 48E Clean Electricity Investment Tax Credit. The ruling, handed down on June 6, 2026, reinstated a key pathway that allows investors to lock in credit eligibility for large-scale wind and solar projects a pathway the IRS had tried to eliminate just last year. The window is not wide open. July 4, 2026 is still the critical deadline, and the government will almost certainly appeal. But for advisors who act quickly, this ruling creates a genuine, time-sensitive planning opportunity. Here is what you need to understand, and what you should be doing right now.
Help Your Clients Implement a Fortune 500 CFO Strategy
Randy Sadler, CIC Services
For decades, some of America’s largest corporations have used a financial strategy that gives their CFOs greater control over insurance costs, helps them finance risks the commercial market handles poorly and creates an opportunity to retain underwriting profit when losses come in below expectations. Approximately 90% of Fortune 500 companies have captive insurance subsidiaries.¹ Historically, the economics favored organizations with substantial capital, large insurance programs and the resources to support their own insurance operations. Small and midsize businesses rarely had the scale to justify the cost and complexity. That equation has changed. A mature network of specialized insurance professionals and structures now allows qualifying privately held businesses to pursue many of the same risk-financing advantages. Federal tax law can further improve the economics for certain smaller insurance companies. For CPAs and tax professionals, this creates an advisory opportunity. The challenge is recognizing which clients could benefit and what conditions must exist before recommending it.
