Direct placement of transferable tax credits.
Bjorklund Consulting works directly with credit sellers and directly with credit buyers, and with intermediaries who hold a direct relationship with one or the other. We do not participate in the general marketplace.
We represent one side of a transaction, or we sit between the buyer and the seller's counsel as the party that brought them together. We do not advise both sides.
What we do
Placement
We bring a seller one buyer, or a buyer one seller, priced all-in before diligence begins. The price quoted to a seller is the price the seller receives. Transaction documents are negotiated by each party's counsel; our role is to set the commercial terms, keep the parties' advisers moving on the same timetable, and close.
Seller diligence advisory
Before a buyer's counsel sees the package, we review it against what that counsel will ask for: registration numbers, production or cost-basis support, prevailing wage and apprenticeship records, beginning-of-construction and placed-in-service support for investment credits, and the foreign-entity and material-assistance confirmations that 2026-vintage credits now carry. The indemnity is sized to the seller: a corporate indemnity, a parent guaranty, or a tax credit insurance policy placed through the seller's insurance broker.
Buy-side sourcing
For taxpayers with capacity to fill, we find supply that has not been shopped, matched to credit type, vintage, size and the indemnity standard the buyer requires. Multi-year programs commit capacity now and take delivery as credits are earned.
Engagement
We are engaged by one party under a written agreement and compensated by that party. Counterparty identities are disclosed under NDA. Bjorklund does not hold funds and does not act as escrow agent.
Who we work with
Sellers
Producers, manufacturers and project owners earning federal or state credits: fuel producers, component and critical-mineral manufacturers, owners of generating, storage and nuclear assets, and developers holding certificated state credits.
Buyers
Corporate taxpayers, banks, insurers and family offices, and the tax counsel and advisers acting for them.
Intermediaries
Brokers, bankers, accountants and advisers who hold a direct relationship with a buyer or a seller and want a placement run to that party's standard.
Counsel
The buyer's and seller's law firms, with whom the transfer agreement, indemnity and election are settled.
Ephraim Olson
Ephraim Olson is the Manager of Bjorklund LLC. He is a tax attorney, a graduate of Harvard Law School, and admitted to practice before the United States Tax Court. His legal practice is in federal energy tax: the §48 and §48E investment credits, the production credits, §6418 transfers, and opportunity zone structuring, including the opinion letters on which investors and insurers rely.
Since 2024 he has advised on more than $250 million of tax credit transfer transactions, on the sell side, the buy side, and as the intermediary between the two, across investment and production credits and with counterparties ranging from private developers to publicly traded companies. That work is the basis for Bjorklund Consulting: the pricing, the diligence standard and the closing mechanics are the same at every size, and a transfer runs best when the person in the middle has sat on each side of it.
He has also spent a career building businesses, which is why Bjorklund is deliberately small. Every engagement is run by the principal.
Credits we place
Every credit transferable under §6418, and state credits that may be sold or certificated for transfer. Federal credits transfer once, for cash, before the seller files for the year the credit was earned; the cash is not income to the seller and not deductible by the buyer. A reference page describes each credit, who earns it, its recapture period, and what a buyer's counsel will ask for.
Contact
Write with the credit type, vintage and approximate amount, or the capacity you want to fill. Replies come from the principal.
- ephraim@bjorklund.consulting
- Phone
- +1 (213) 500-9105
- Address
- Bjorklund LLC
1607 Avenida Ponce de León, Ste. GM6 #773
San Juan, Puerto Rico 00909