• In relation to our industry, the IRA is new legislation that incentivizes renewable energy installations by providing a 30% tax credit of the total installation. Homeowners have an opportunity to claim a 30% tax credit under Section 25D for qualified solar electric property expenditures. Business have an opportunity to claim the 30% tax credit can under Section 48E.
• The Domestic Content Bonus Credit (DCBC) provides businesses an ADDITIONAL 10% tax credit of the installation under Section 48E, if (1) all steel and iron components are made in the U.S., and (2) the non-steel/non-iron manufactured products in the project meet the Adjusted Percentage Rule.
• For 2024 and 2025 the Adjusted Percentage Rule is met if 40% of the manufactured product cost is from domestic sources. After 2025, the percentage will increase.
• Individuals cannot get the DCBC under Section 25.
• Businesses such as EPCs, financiers, and TPOs could see up to 40% (i.e., 30% base + 10% in bonus) in tax credits for a solar installation if that installation has domestic steel and iron components and meets the domestic cost percentage threshold.
• Anyone interested in taking advantage of the IRA and DCBC must contact their tax professional to determine eligibility. While Unirac is not tax consultant or other tax professional and is not providing legal opinions or advice through this document. The discussion here is for information purposes only.

There are two main methods for calculating the domestic cost percentage:

• Cost method: actual domestic manufacturing costs is divided by total manufactured products cost. The cost method requires all manufacturers to share cost data with the entity claiming the tax credit.
• “Safe Harbor” method: recognizing that most manufacturers will not openly share cost information, the IRS established Safe Harbor Guidance which allows tax payers to assume cost percentages for manufactured product components in an applicable project. The Safe Harbor method has established percentages that count toward the current 40% threshold.

• Under the Safe Harbor method, a fully domestic non-steel rooftop racking may contribute up to 25.8% of the needed 40% in an MLPE-based system or may contribute 37% in a string-inverter-based system.
• Unirac has a fully domestic solution: Solarmount Light rail with Unirac legacy clamps and domestic Stronghold Butyl attachments. While Unirac cannot provide tax advice if a particular tax payer will get the DCBC with this system, Unirac can provide documentation indicating that its fully domestic solution is manufactured in the United States.
• Under the current Safe Harbor guidance, taxpayers may have a path to reaching the 40% threshold using Unirac’s fully domestic solution and partially-domestic inverters available on the market, regardless of whether the modules in the system are domestic.

Under the Safe Harbor Guidance, the IRS has provided assumed cost percentages for two categories of manufactured product components for non-steel roof racking: “rails” and “fasteners.”

• While the Safe Harbor Guidance provided the assumed percentages–8.6% for rail, 11.1% for fasteners in MPLE systems or 12.3% for rail and 16.0% for fasteners in String inverter systems—the Guidance does not define a “rail” or a “fastener.”
• The good news is that Unirac offers a complete domestic system! Regardless of how the IRS later clarifies what is a “rail” or what is a “fastener,” as system with Unirac’s SolarMount® Light rail, Unirac legacy clamps, and domestic Stronghold Butyl attachments provide maximum opportunity for a clear path to claim the DCBC without ambiguity.
• Unirac has a full suite of domestic products, and those wishing to claim the credit should work with their tax advisors to determine their individual path to the DCBC, either using the Safe Harbor Method or the Cost Method.
• Unirac is a manufacturer, and we can provide documentation to support that our products are manufactured domestically. Each individual taxpayer may elect how to use that information best for tax advantage.

In most cases, installers cannot directly claim Section 48 tax credits and the DCBC. Only businesses that own a solar installation can do so. Please note that Unirac is not providing tax advice here. If you have questions about whether you can claim tax credits under Section 48 or the DCBC, please consult your tax advisor.

Installers may still reap the benefits of the DCBC depending on their relationship with financing partners.

We are currently working with Enphase and SolarEdge on MLPE-based systems to provide customers with a path to the 40% DCBC threshold without the need for modules in 2024 and 2025. This includes semi-domestic inverters with our fully domestic Solarmount system and fully domestic inverters with any of our domestic rail offerings.

While some of our products were Made in the USA before, we must now have tighter controls to ensure that a particular product—with a specific part number—will always be domestic. With the IRA, we have a lot more administration, control, and tracking, increasing cost. Also, our domestic suppliers are seeing increase in demand and have limited capacity, which increases costs. We are trying to manage these costs as best we can as demand increases and capacity starts to open.

On average, we assume a domestic content solar system is ~$3.50-$4.50 per watt. The 10% domestic content bonus credit is applied to the cost of the entire system, not just the domestic parts. So, while a 100% domestic racking system is ~$0.02-$0.04 more per watt, the 10% tax credit for the whole system will be on the order of ~$0.35-~$0.45 per watt!

The Unirac Domestic Price List is our full list of US-manufactured products. We guarantee that these parts, all denoted with the suffix –US, are manufactured, produced, and assembled in the US. Therefore, the products on this list meet the Inflation Reduction Act (IRA) and Buy America Act (BAA) requirements for domestic, Made in the USA parts. If the product you are searching for is not on the list, we cannot currently consider it domestic content.

Yes! We are currently working on sourcing RM 10 EVO and ECOFOOT clamps domestically to have a 100% domestic solution for commercial bay systems, available at the end of 2024. We also plan to have NXT module clamps available starting Q1 2025.

We are currently working with finance companies and large installers to understand demand and adjust our domestic production accordingly. We are already increasing production of domestic Solarmount rails and have kicked-off Solarmount Butyl production. Lead-times will be a little fluid for the next few months as we understand and adjust to meet demand, but we aim to keep them close to our standard lead times. If distributors want to stock both domestic and standard product to help customers with lead times, they will need to ensure they can segregate the materials properly to avoid issues with tax auditing.

We are working with suppliers throughout the US for our US-manufactured parts. Many of the suppliers are right here in Albuquerque close to our headquarters! We also have production capabilities at our Albuquerque headquarters, with many parts stamped, drilled, assembled, and packaged within our own four walls. This is why we have been able to respond so quickly to the domestic content demand: we have the capabilities to manufacture in-house!

Unirac has a general domestic content letter that consolidates the product line letters with the domestic content parts list. This letter should be sufficient for the majority of customers seeking BAA and IRA guidance.

For customers who are applying for the DCBC under the IRA, have a path forward, and have ordered our domestic content products, we can provide a letter indicating that certain Unirac’ products are domestically manufactured a case-by-case basis. These letters ARE NOT GUARANTEES that the customer’s project will meet the requirements for the DCBC. They simply define how Unirac views our domestic products and guarantees our domestic parts (those with the –US suffix) are manufactured in the US and meet the requirements for domestic content.