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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.

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This virtual forum hosted by Marshall & Stevens brings together senior leaders from private equity, 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.

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When Are Valuation Opinions Needed in Structured Finance?

Structured finance transactions often involve complex assets, lease arrangements, and layered ownership structures. In these situations, transaction advisors, investors, and financial institutions need clear, supportable answers to specific valuation questions.

These analyses are used to support financing decisions, meet tax requirements, and satisfy financial reporting obligations.

Marshall & Stevens provides independent value opinions that help parties understand how assets are expected to perform, how long they will remain useful, and what they may be worth at different points in time.


What Types of Valuation Questions Are Addressed?

Structured transactions require more than a single estimate of value. They often involve a set of related analyses that address different economic, tax, and accounting considerations.

Common opinions include:

  • Economic compulsion
    Whether a lessee is financially likely to exercise a purchase option or continue a lease
  • Economic useful life
    How long an asset is expected to generate economic benefit
  • Future value assessments
    Estimated value at the end of a lease or at a specified future date
  • Equity valuation by class
    Allocation of value across different ownership interests
  • Limited use analysis
    Whether an asset has a specialized use that limits its marketability
  • MACRS classification (cost segregation)
    Identification of asset classes for depreciation and tax treatment
  • Fair market value
    The price an asset would achieve in an open and competitive market
  • Purchase option analysis
    Evaluation of fixed-price or bargain purchase options
  • Repowering (80/20) analysis
    Assessment of asset replacement or upgrade structures for tax purposes
  • Residual value
    Expected remaining value at the end of an asset’s useful life or lease term

Each of these analyses addresses a different decision point within a transaction, from structuring and pricing to compliance and reporting.

What Types of Assets and Industries Are Involved?

These valuation issues arise across a wide range of asset-heavy and infrastructure-driven industries where long-lived assets and lease structures are common.

Marshall & Stevens has experience with assets and projects in:

This range reflects the types of assets typically involved in structured finance transactions, where physical assets, contracts, and tax considerations intersect.


Why Tax and Regulatory Compliance Matters

Many structured finance transactions are evaluated under IRS guidelines that determine whether a lease qualifies as a “true lease” or must be treated as a financing arrangement.

These distinctions affect:

  • Tax treatment of income and depreciation
  • Financial reporting classification
  • Transaction structuring and risk allocation

Marshall & Stevens works alongside transaction advisors, investors, lessors, and tax counsel to ensure that valuation analyses align with these requirements and support the broader transaction.


How Marshall & Stevens Supports the Transaction

The role of valuation in these transactions is not isolated. It sits within a larger process that includes legal structuring, tax analysis, and financing decisions.

Marshall & Stevens coordinates with all relevant parties to:

  • Provide independent, supportable value opinions
  • Align analyses with tax and reporting requirements
  • Support documentation used in transaction execution

This helps ensure that the transaction can move forward with a clear understanding of value, risk, and compliance considerations.

 
 

Energy & Infrastructure

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.

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How Marshall & Stevens can help with Project Finance

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.

Frequently Asked Questions

What is project finance valuation and why is it important?
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Project finance valuation involves determining the value of assets and cash flows used in structured financing arrangements such as leases, sale-leasebacks, and tax equity investments. These valuations are critical because lenders, investors, and tax authorities require independent value opinions to support financing, tax compliance, and financial reporting.

What types of transactions require project finance valuation services?
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Project finance valuations are commonly required for structured finance transactions, including lease financings, inverted leases, synthetic leases, and tax equity investments. These transactions often involve complex structures that require multiple valuation opinions rather than a single point-in-time asset value.

What valuation analyses are typically included in project finance engagements?
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A project finance valuation may include a range of analyses such as economic useful life, residual value, fair market value purchase options, end-of-lease value, equity valuation by class, and MACRS classifications (cost segregation). These analyses help ensure transactions meet tax, accounting, and financing requirements.

Who relies on project finance valuation opinions?
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Project finance valuation services are used by a wide range of stakeholders, including investors, lenders, developers, tax advisors, attorneys, and financial institutions. These parties rely on independent valuation opinions to structure transactions, satisfy regulatory requirements, and support decision-making.

Why is independent valuation critical in structured finance transactions?
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Independent valuation is essential because structured finance transactions must comply with IRS regulations and financial reporting standards. A defensible, third-party valuation helps ensure the transaction is properly structured, supports tax positions, and withstands scrutiny from auditors, regulators, and counterparties.

Why Marshall & Stevens

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.

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94 years since founding
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Client Highlights

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