A Practice Note discussing key issues and risk mitigation strategies for buyers seeking to participate in the rapidly growing market for clean energy tax credits under Sections 45 and 48 of the Internal Revenue Code, including the risk the Internal Revenue Service may disallow or recapture the credit for failure to comply with the applicable regulations. This Note also discusses mechanisms buyers can use to mitigate these risks including due diligence, indemnification, representations and warranties, and tax credit insurance.