In 2026, energy is no longer evaluated as a readily available, low-cost input or a purely environmental choice. It is being priced as constrained, strategic infrastructure that’s exposed to grid bottlenecks, AI-driven demand, geopolitical supply-chain risk, and rapidly evolving federal priorities directly influencing Washington-sponsored incentives.
For investors, developers, and advisors, the core question is no longer how clean an asset is, but whether it is reliable, still financeable under a host of new rules, and readily deployable for near-to-midterm development objectives.
This virtual forum hosted by Marshall & Stevens in May of 2026 brought together senior leaders from international energy development, data center infrastructure, regulatory policy, and project finance law for a live, unscripted conversation examining how energy assets are being repriced, restructured, and reallocated in 2026 and beyond.
Watch the recorded discussion to hear the full conversation.
Who Should Watch:
PE Firms | Infrastructure & Energy Funds | SPACs | Accountants | Attorneys | Energy Developers | Data Center & AI Infrastructure Investors
Recent changes to the federal tax code have created strict timelines for renewable energy projects to qualify for investment tax credits (ITC) and production tax credits (PTC).
To meet these deadlines, many project owners are choosing to repower existing facilities rather than build new ones. Repowering allows a project to upgrade or replace components while still qualifying for tax incentives.
At the same time, rapid data center development across the U.S. is increasing demand for reliable energy sources. This has further accelerated investment in both renewable and conventional energy infrastructure.
These trends have increased the need for independent valuation analyses to support repowering strategies and related transactions.
A key issue in repowering is whether a project qualifies for tax credits under IRS guidance. One of the most important tests is the “80/20 Rule.”
In simple terms, this test evaluates whether:
This determination directly affects eligibility for tax credits, which can significantly impact project economics.
Marshall & Stevens provides valuation analyses that help clients apply this rule, particularly for wind energy projects where it is most commonly used.
Repowering and related valuation issues arise across a wide range of energy and infrastructure assets.
Renewable energy projects include:
Conventional energy projects include:
These projects often involve long-lived, capital-intensive assets where tax treatment, financing structure, and future performance all depend on accurate valuation.
Energy projects frequently rely on multiple revenue streams and incentives, including:
Valuation plays a central role in determining how these benefits are recognized, allocated, and monetized within a transaction.
Marshall & Stevens works with investors, developers, legal counsel, and auditors to ensure that valuation analyses reflect current guidance, rulings, and interpretations.
Energy and infrastructure transactions typically require more than a single valuation. Assignments often include:
These analyses support decisions across financing, reporting, tax compliance, and dispute resolution.
Some energy assets operate within regulated utility structures, which introduces additional complexity.
Regulated utilities earn revenue based on approved rates set by federal and state agencies. These rates are designed to allow:
Valuation in this context requires understanding:
Analyses often incorporate:
Clients include:
These stakeholders rely on independent valuation opinions to support transactions, meet regulatory requirements, and understand the financial implications of complex energy investments.
Energy transactions often involve coordination across multiple parties, including investors, tax advisors, legal counsel, and auditors.
Marshall & Stevens provides independent valuation analyses that help align these stakeholders by:
This role is especially important in repowering transactions, where qualification for tax credits depends on how value is measured and allocated.
We provide a broad portfolio of independent valuation services to traditional and renewable energy enterprises that generate, distribute, and transmit oil, gas, biofuel, and electricity as well as those who service these enterprises. Federal and state renewable energy incentives are responsible for a monumental increase in renewable energy project finance valuations.
Municipalities, utilities, infrastructure funds, public and private enterprises engage us because of the multi-disciplinary specialists we employ, the experience of our professionals, and the client service focus of our firm.
Our team collaborates with our internal multi-disciplinary professionals to provide the value analyses and fresh independent opinions to fiduciaries, financing sources and investors for public and private company transactions.
Marshall & Stevens provides valuation and advisory services across a broad spectrum of energy assets, including renewable technologies such as solar, wind, geothermal, renewable natural gas, and battery energy storage systems, as well as conventional assets like oil, gas, coal, and nuclear facilities. Their expertise also extends to energy transmission, distribution, and supporting infrastructure.
Clients include energy developers, utilities, municipalities, infrastructure funds, and domestic and international financial institutions. These stakeholders rely on independent valuation analyses to support transactions, financial reporting, tax compliance, and investment decision-making.
Typical engagements include project finance valuations, fairness and solvency opinions, purchase price allocations, portfolio valuations, cost segregation analyses, and tax-related reporting. These services support financing, mergers and acquisitions, restructuring, and ongoing financial reporting requirements.
Federal and state incentives—such as investment tax credits (ITC), production tax credits (PTC), and renewable energy credits (RECs)—play a significant role in determining project economics and valuation. Properly analyzing and monetizing these incentives is critical for structuring transactions and supporting defensible valuations.
Energy projects are highly capital-intensive and often financed through complex structures such as tax equity investments, leases, and sale-leasebacks. These transactions require detailed analysis of cash flows, regulatory frameworks, and asset performance to produce independent valuation opinions that meet accounting, tax, and investor requirements.
Marshall & Stevens provides Fairness and Solvency Opinions, valuation analyses, investigative accounting, and expert witness services to assist public and private clients with their important transactions and litigation matters.
Here are a few client success stories from public and private companies we’ve worked with
