A US-based critical mineral producer sought to monetize its 2024 §45X tax credits. Section 45X credits, including for critical minerals, are a new category of transferable tax credits. Federal legislation passed in 2022 created the §45X advanced manufacturing production tax credit, which incentivizes a range of manufacturing activities for clean energy, including the extraction and processing of 50 critical minerals identified by the US Geological Survey.
Since then, §45X credits have grown popular among tax credit buyers, thanks in part to their relatively low risk and straightforward due diligence process. Advanced manufacturing made up the single largest technology category in the 2024 transferable tax credit market at 33.7%. Crux’s 1Q2025 Market Update found that about 25% of commercial bids placed on Crux in the first quarter of 2025 were for advanced manufacturing tax credits.
Against this backdrop, the mineral producer was looking to optimize its tax credit sale. It had sold 2023 credits previously, but hoped to find a partner to help run a more competitive bidding process.
In Crux, the mineral producer found a dedicated partner that not only optimized the terms of the transaction, but handled the transaction from credit listing to deal closing.
Crux’s leading marketplace enabled the company to list its credits quickly and connect with multiple buyers. Within two weeks, Crux delivered three bids, taking advantage of strong demand for §45X credits.
The fast speed to market impressed the producer and helped prove that transferable tax credits could serve as a reliable source of cashflow.
The producer relied on Crux’s expert as an extension of its own team. Crux managed all aspects of the transaction, from initial bid evaluation to final closing. This included structuring guidance, document preparation, and facilitation of third-party diligence.
Because §45X credits are based on eligible production costs, buyer diligence relied heavily on accounting verification. Crux coordinated information flow from producer’s accountants to ensure the buyer understood and was comfortable with the underlying cost substantiation.
Crux’s team also brought deep experience to the transaction. Since completing one of the market’s first §45X transactions, Crux has worked to bring standards to the credit category, including by creating a §45X-specific diligence checklist.
That experience and expertise were critical in navigating a change in guidance that occurred before the producer met with buyers. In its draft guidance published in November 2023, the Internal Revenue Service (IRS) prohibited including mineral acquisition costs in calculating the value of the §45X tax credit. The final guidance released in October 2024, however, allows the inclusion of certain material costs, including extraction costs.
The regulatory change meant that the critical mineral producer’s eligible costs — and therefore its credit volume — increased overnight for tax years 2023 to 2024. Based on deep policy expertise and close tracking of the anticipated IRS guidance, Crux worked with the producer to recalculate its credit volume ahead of formal rulemaking. The Crux team then found the producer a sophisticated buyer who was willing to begin diligencing the tax credit purchase based on the prospective regulations from the IRS. The buyer trusted Crux’s market view and knew that Crux would be following the latest guidance, so felt comfortable starting the diligence process while waiting on the final regulations.
The buyer’s willingness to begin due diligence led to a faster transaction close.
By working with Crux, the critical mineral producer optimized the deal terms, achieved more competitive pricing, and structured a more favorable deal compared to its previous deal. The transaction closed on time and delivered timely working capital that the producer reinvested in its business, ultimately making it more competitive with global producers.
With tax credit monetization integrated as part of its broader business strategy, the producer is looking to do more transactions. Crux is supporting the company with a potential forward strip of credits and exploring how transferable credits can support additional financing strategies.
Learn more about how the Crux team can support you in getting the most competitive deal terms for your tax credits. Contact us today.