Foss & Company Q3 2026 Report: One year since the One Big Beautiful Bill

What does a year of the One Big Beautiful Bill (OB3) look like from our perspective? In Q3 2026, phase-out timelines and placed-in-service deadlines came up in many of our conversations, along with Foreign Entity of Concern (FEOC) compliance and a Historic Tax Credit (HTC) market that stayed selective. Here is how the last quarter went for our team at Foss & Company.

 

What we’ve been talking about

We released Episode 13 of our Tax Credits Today podcast, “Managing Legal Risk in Tax Equity: Structuring, Recapture & Compliance.” Kevin Haley, SVP of Investments, sat down with Sarah Lieber, our General Counsel, to walk through the legal questions that come up when structuring a tax equity deal.

We also published pieces on Missouri’s HTC expansion under HB 3080, tax insurance after OB3 and the role the tax code has played in building America over 250 years.

 

What we’ve been working on

Q3 kept us busy on the deal side. The energy and infrastructure team worked on solar, battery storage, solar + battery and distributed energy  transactions. This quarter, we entered the microgrid sector with a tax equity investment in a transit project in Montgomery County, MD. On the HTC side, we invested in historic rehabilitation projects across Ohio, North Carolina, Virginia, New York and Indiana.

 

Out in the field

Our team sponsored or attended 11 events this quarter, from Infocast PowerUp Data Centers in Austin to the COST 57th Annual Meeting in San Antonio, TX. Team members also took part in panels on topics from microgrids to nuclear to project finance. Trent Douglass, Project Finance Associate, represented us on a panel about standardizing microgrids for scale at Great Transformation 2026. Ella Rose, VP of Construction Engineering, gave a solo presentation on financing nuclear development at the 7th Texas Energy Forum. Sophie Brkovic, VP of Project Finance, spoke on the state of energy project finance at Ascend Summit 2026.

 

New faces

In Q3, we welcomed Stran Summers, VP of Investments; Virginia Tannehill, VP of Transfer Credits, Investments; Chris Dell Isola, VP of Investments; and Remy Heinala, Analyst, Project Finance, Energy & Infrastructure.  Each brings deep industry experience to our growing team and further strengthens how we serve our clients and partners.

 

Where we’re headed

As solar and wind credits approach their sunset, we are already sourcing and investing in opportunity sets that extend beyond these two technologies. We closed a battery energy storage transaction in Hidalgo County, TX, this quarter, and we continue to build our presence in advanced manufacturing and nuclear alongside our established work in transferable credits, Investment Tax Credits (ITCs), HTCs, Production Tax Credits (PTCs) and more. Heading into the final quarter of the year, we’re committed to disciplined execution across all of it.

Questions about FEOC compliance, HTC opportunities or navigating the solar and wind credit sunset? Connect with Foss & Company today.