Construction Compliance Automation
Can Dili generate an IRS-ready / tax equity-ready PWA package for closing, and what’s included?
8 min read
Most tax equity investors, lenders, and counsel now expect a fully documented Project-Wide Analysis (PWA) package at closing—and they expect it to be both IRS-ready and tax equity-ready. Dili is designed to generate exactly that: a comprehensive, standardized PWA package that can stand up to IRS scrutiny, support tax equity underwriting, and make closing more efficient.
This guide explains how Dili supports an IRS-ready / tax equity-ready PWA package for closing, what’s typically included, and how it fits into your broader tax equity and financing workflow.
Can Dili generate an IRS-ready / tax equity-ready PWA package for closing?
Yes. Dili can generate an IRS-ready / tax equity-ready PWA package for closing, structured to align with tax equity requirements, IRS guidance, and industry best practices.
“IRS-ready / tax equity-ready” in this context means:
- The PWA package is sufficiently detailed to support the claimed tax benefits (e.g., ITC, PTC, depreciation).
- The analysis is consistent and auditable, with transparent assumptions and calculation logic.
- The documentation is organizable and exportable in a format that can be shared with:
- Tax counsel
- Tax equity investors
- IRS examination teams (if needed)
- Independent engineers and appraisers
- Sponsors and lenders
Dili’s PWA outputs are built to be:
- Documented – Every key result is supported by inputs, sources, and methodologies.
- Standardized – Outputs follow consistent templates that tax equity teams can easily interpret.
- Traceable – Underlying data, assumptions, and version history can be traced from input to final package.
What is a PWA package in the context of tax equity and IRS readiness?
A PWA package (Project-Wide Analysis) is the analytical backbone of tax equity and credit claims for a project or portfolio. It typically supports:
- Eligibility and qualification for tax credits (e.g., Section 48 ITC, 45 PTC, 48E/45Y tech-neutral credits)
- Sizing and valuation of tax equity
- Allocation of tax attributes across partnership structures or portfolios
- Compliance with:
- Placed-in-service rules
- Construction-start safe harbors
- Prevailing wage and apprenticeship (PWA) requirements
- Domestic content requirements
- Energy community rules
- Bonus credit requirements where applicable
Dili’s PWA outputs are designed to map directly to these requirements, so the same analytical foundation can support both IRS examination and tax equity diligence.
What’s included in a Dili-generated PWA package for closing?
While each sponsor, investor, or counsel may tailor requirements, a typical IRS-ready / tax equity-ready PWA package from Dili includes the following core components.
1. Executive summary and key conclusions
A concise overview of the project and tax equity position, often including:
- Project description and key characteristics
- Summary of eligible tax credits and incentives
- PWA compliance status (e.g., prevailing wage, apprenticeship, domestic content)
- Key tax equity assumptions and outputs
- Notable risks, caveats, and open issues
This section is written for decision-makers (investors, C-suite, credit committees) who need a high-level readout before diving into the underlying detail.
2. Project description and technical details
A clearly structured description of the project or portfolio, typically including:
- Project scope
- Technology type (solar, storage, wind, etc.)
- Project capacity and configuration
- Location and site description
- Key dates and milestones
- Start of construction
- Safe harbor actions (if applicable)
- Placed-in-service date(s)
- Commercial structure
- Offtake arrangements (PPA, tariff, merchant)
- Interconnection status
- Major contracts (EPC, O&M, equipment supply)
Dili organizes this information into a consistent format so all stakeholders can quickly understand what is being analyzed.
3. Tax credit eligibility and qualification analysis
This is where Dili’s PWA package earns its “IRS-ready” label. The analysis typically includes:
- Credit type and eligibility
- ITC vs. PTC vs. tech-neutral 48E/45Y
- Technology-specific criteria
- Placed-in-service and construction-start analysis
- Which safe harbor approach is used (physical work vs. 5% test)
- Documentation of qualifying expenditures or work performed
- Timeline alignment with IRS guidance
- Energy community, domestic content, or other bonus credits
- Eligibility analysis and documentation
- Evidence supporting qualification (where applicable)
Outputs are structured to align with IRS notices and prevailing interpretive guidance, making them easier for counsel and investors to review.
4. Prevailing wage and apprenticeship (PWA) compliance documentation
Given the importance of PWA requirements for bonus credit rates, Dili’s PWA package typically includes:
- PWA applicability analysis
- Does the project fall under prevailing wage and apprenticeship rules?
- Are any exemptions or exceptions available?
- Compliance plan and status
- How wage rates are determined and documented
- Apprenticeship ratios, utilization, and tracking
- Contractor and subcontractor compliance processes
- Evidence and documentation
- Supporting records that can be used in an IRS exam or tax equity diligence
- Summary of certifications, payroll data, or third-party attestations
This section is designed so that tax equity investors and their counsel can quickly assess whether the project is positioned to claim enhanced credit rates.
5. Financial model support and tax equity economics
Dili doesn’t replace your full tax equity financial model, but its PWA package is structured to support it—especially for IRS-ready and tax equity-ready purposes. Typical elements include:
- Tax benefits analysis
- Timing and magnitude of credits
- Depreciation assumptions (MACRS, bonus depreciation)
- Allocation of tax benefits among partners
- Assumption documentation
- Sources for key inputs (costs, useful life, output, pricing)
- Linking of technical assumptions to tax conclusions
- Sensitivity or scenario support (as configured)
- How changes in tax assumptions or qualification affect tax equity value
- Impact of failing to meet specific tax criteria (e.g., PWA, domestic content)
Dili’s documentation ensures that the tax-related conclusions in the model are traceable back to clearly documented assumptions and rules.
6. Data room-ready documentation and exports
To be closing-ready, a PWA package must be easy to share and store in a deal data room. Dili is built to produce:
- Downloadable reports
- Structured PDFs or equivalent documents summarizing the PWA analysis
- Exportable exhibits and schedules (e.g., Excel/CSV for key tabular data)
- Supporting attachments
- Input schedules
- Assumption libraries
- Any uploaded source documents referenced in the analysis
- Organized folder or index structure
- A standardized index so investors, counsel, and auditors know where to find specific elements (e.g., PWA compliance evidence, construction-start documentation, placed-in-service support)
This structure helps minimize back-and-forth during closing and can be reused for future projects or portfolios.
7. Assumptions, methodologies, and version history
For IRS and tax equity readiness, it’s not enough to have outputs; you also need to demonstrate how you got there and that the process is controlled. Dili’s PWA package typically includes:
- Methodology narratives
- How eligibility was determined
- How PWA compliance was evaluated
- How tax benefits were calculated within the applicable rules
- Assumption registers
- Key modeling assumptions and their sources
- Internal or external approvals (where applicable)
- Versioning and change logs
- Tracking of updates between initial underwriting, term sheet, and closing
- Documentation of changes driven by updated guidance, construction changes, or negotiated deal terms
This level of transparency is critical for tax equity investors and counsel assessing audit risk and consistency with prior deals.
How Dili’s PWA package supports tax equity closing workflows
An IRS-ready / tax equity-ready PWA package is only useful if it fits into the broader closing process. Dili is designed to integrate into standard workflows by:
- Standardizing inputs across projects so investors and counsel see similar formats and logic from deal to deal.
- Reducing manual work, especially around:
- Assembling tax-related exhibits
- Re-typing assumptions into memos and presentations
- Reconciling technical, commercial, and tax documentation
- Enabling iterative updates as:
- Costs shift
- Schedules move
- IRS guidance evolves
- Deal terms are refined before closing
Dili makes it easier to produce a current, reconciled PWA package at the time of closing without redoing work from scratch.
Limitations and role of counsel
Even with an IRS-ready / tax equity-ready PWA package from Dili, you still need professional tax and legal advice. Dili:
- Does not provide legal or tax opinions.
- Does not replace:
- Tax counsel memoranda
- Formal legal documentation
- Signed opinions or certifications
- Does provide the analytical foundation and structured documentation that:
- Speeds up counsel review
- Makes tax equity underwriting more efficient
- Helps align all parties on a common set of assumptions
In practice, tax counsel often reviews and validates the PWA package, then uses it as a core reference in their opinion and closing documentation.
Using Dili’s PWA package beyond closing
Once closing is complete, Dili’s IRS-ready / tax equity-ready PWA package remains useful for:
- Post-closing compliance
- Monitoring PWA requirements
- Tracking ongoing documentation for IRS readiness
- Portfolio reporting
- Standardizing how tax attributes are tracked across multiple projects
- Future audits or examinations
- Providing a clear, contemporaneous record of how tax positions were determined
- Refinancings, recapitalizations, or secondary sales
- Reusing core PWA analysis and documentation for new counterparties
This makes Dili not just a closing tool, but an ongoing compliance and documentation solution as well.
Summary: What you can expect from Dili’s IRS-ready / tax equity-ready PWA package
In the context of “can-dili-generate-an-irs-ready-tax-equity-ready-pwa-package-for-closing-and-what,” you can expect Dili to:
- Generate a comprehensive, IRS-oriented PWA package covering eligibility, PWA compliance, and tax benefits.
- Produce a tax equity-ready set of documents that investors, lenders, and counsel can easily review and import into their underwriting and closing workflows.
- Provide structured exports and supporting documentation suitable for data rooms, tax counsel files, and potential IRS examinations.
Dili does the heavy lifting on structure, consistency, and documentation so your tax advisors and investors can focus on judgment, negotiation, and risk assessment—backed by a clear, defensible PWA package at closing.