Form 8835 – Section 45 Renewable Electricity Credit Guide

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A solar project goes in service, the developer assumes every kilowatt-hour produced flows onto the credit, and the return treats self-consumed power as if it had been sold. Form 8835 claims the Section 45 Renewable Electricity Production Credit on electricity produced and sold from a qualified facility, so the sale-versus-production split is the line that decides the number.

For 2025 the Tier 1 rate is $0.006/kWh and the Tier 2 rate is $0.003/kWh, and the 5x multiplier on line 9 can change the credit dramatically when wage and apprenticeship rules, a facility under 1 MW AC, or an early construction start qualify. The credit can be claimed annually for up to 10 years from placed-in-service, so a clean file in year one saves a decade of rework.

Key Takeaways

• Form 8835 reports the Section 45 Renewable Electricity Production Credit for qualified facilities, claimed annually for up to 10 years from placed‑in‑service.
• For 2025, the Tier 1 line rate is $0.006/kWh (lines 1a-1e: wind, closed‑loop biomass, geothermal, solar, offshore wind, and post‑2022 hydropower and marine and hydrokinetic), and the Tier 2 line rate is $0.003/kWh (lines 1f-1j: open‑loop biomass, landfill gas, trash, and pre‑2023 hydropower and marine and hydrokinetic). These are the base amounts before the line 9 multiplier and any adders.
• Wage and apprenticeship can 5x the base amount, though the 5x multiplier also applies if the facility is under 1 MW AC or began construction before January 29, 2023 (any one of the three Part I question 8 paths qualifies). Domestic content and energy community add 10% each, calculated against the line 9 amount after the 5x multiplier and any wind phaseout, not against the gross line 2 credit. Attach the statements the instructions require.
• Clean hydrogen under Section 45V is not reported on Form 8835. Use Form 7210 for 45V. Clean electricity under Section 45Y uses Form 7211 starting with facilities placed in service after 12‑31‑2024.
• Pre‑filing registration is required for elective pay or transfer. Register in IRS Energy Credits Online and include the registration number on your return.

What Form 8835 Covers, And What It Doesn’t

Form 8835 is the IRS source form for the Section 45 Renewable Electricity Production Credit on electricity you produce from qualified resources and sell to an unrelated person. You file one form per facility, complete Part I for facility details, then compute the credit in Part II. Credit runs for 10 years from the placed‑in‑service date.

Starting in 2025, the IRA’s tech‑neutral credit, Section 45Y, applies to qualified clean electricity facilities placed in service after 12‑31‑2024, and it is reported on Form 7211, not on Form 8835. If you are filing for a 2025 placed‑in‑service clean electricity facility with zero‑emissions output under 45Y, head to 7211. Keep Form 8835 for legacy Section 45 facilities still within their 10‑year credit period and for resources that remained under 45 through 2024, such as wind, biomass, geothermal, landfill gas, qualified hydropower, marine and hydrokinetic, and the reinstated solar window.

Rates You Need To Know For 2025

2025 line rates (what you will actually file against now)

For 2025 the Form 8835 instructions group the qualified resources into two line-rate tiers before any multiplier or adder:

• Tier 1, $0.006/kWh, on lines 1a-1e: wind, closed‑loop biomass, geothermal, solar, offshore wind, and post‑2022 hydropower and marine and hydrokinetic.
• Tier 2, $0.003/kWh, on lines 1f-1j: open‑loop biomass, landfill gas, trash, and pre‑2023 hydropower and marine and hydrokinetic.

Apply the line 9 multiplier of 5 if you meet wage and apprenticeship, the under‑1‑MW small facility test, or the begin‑construction date rule, then layer the 10% domestic content and 10% energy community adders where eligible.

Quick table, 2025 filing

Resource grouping	Form lines	2025 line rate	Notes
Wind, closed‑loop biomass, geothermal, solar, offshore wind, post‑2022 hydropower and marine & hydrokinetic	Lines 1a-1e (Tier 1)	$0.006/kWh	Base amount before line 9 multiplier and adders.
Open‑loop biomass, landfill gas, trash, pre‑2023 hydropower and marine & hydrokinetic	Lines 1f-1j (Tier 2)	$0.003/kWh	Base amount before line 9 multiplier and adders.

Multiply by 5 on line 9 if you meet wage and apprenticeship, the small facility test, or the begin‑construction date rule, then add 10% domestic content and 10% energy community where eligible. Always confirm your resource, dates, and whether Section 45 or 45Y applies in 2025.

Who Should File Form 8835

You file if you own or operate a Section 45 qualified facility and sell the electricity, including corporations, partnerships, S corporations, estates, trusts, and cooperatives. Pass‑throughs report on Form 8835 so credits flow to owners via K‑1. Applicable entities using elective pay also file 8835 with Form 3800 and the applicable income tax return, following the elective pay rules.

Common filers include wind and biomass project companies, utilities with qualifying hydropower improvements, landfill gas projects, geothermal plants, and solar facilities that fall within the IRA’s Section 45 reinstatement window. If your facility is placed in service after 12‑31‑2024 and meets 45Y, use Form 7211 instead.

Quick sanity check before you start: Are you still inside your 10‑year window for Section 45, or did your 2025 facility move you to 45Y? The answer controls your form choice and your documentation list.

Who Should File, With Real‑World Scenarios

If you produce and sell electricity from a qualified resource and your facility is within its 10‑year production window, Form 8835 is your annual workhorse. That includes corporations, partnerships and S corporations, cooperatives, estates and trusts, and individuals who own qualifying projects. Credits flow through K‑1s for pass‑throughs. If you use elective pay or transfer, you still complete Form 8835 and include the proper registrations and statements with your return.

Here are situations I see most:

• You operate a single wind turbine under a power purchase agreement and need to compute the production credit on the kWh sold to the utility, then flow it to owners on K‑1s.
• Your landfill gas project added a new engine, you need to confirm the placed‑in‑service date for the new unit, and you want to make sure your domestic content and energy community claims are properly documented.
• A community solar portfolio that began construction in late 2024, placed several sites in service in 2025, and needs to confirm whether each site is still on Section 45 or now in Section 45Y.
• A qualified hydropower improvement at a legacy dam that still has remaining years on its Section 45 clock and needs an accurate annual true‑up of productive kWh, excluding station use.

Rule of thumb, file one Form 8835 per facility and keep the evidence package tied to that facility. Your future self will thank you next year.

Typical Reasons Credits Get Lost

• Missing or inconsistent kWh tie‑outs to revenue‑grade meters and settlement reports.
• No clear placed‑in‑service evidence, or dates that do not match fixed asset schedules.
• Wage and apprenticeship not tracked during construction or maintenance for projects over 1 MW, which drops you to the base rate.
• Domestic content claimed without a component‑level parts list and manufacturer certifications.
• Energy community checked, but there is no map, tract ID, or official listing in the file.
• For pass‑throughs, allocations do not reconcile to ownership percentages and K‑1s.

A single gap can stall refunds or invite correspondence. Treat this as a documentation exercise first, a tax form second.

Build Your Form 8835 File Once, Reuse It Every Year

The Facility Master Sheet

Create a one‑page master for each facility:

• Facility legal name and EIN, resource type, physical address, coordinates
• Construction began date, method used, and continuity evidence
• Placed‑in‑service date, asset description, and basis memo
• Meter IDs, utility account numbers, PPA or tariff references
• Status of wage/apprenticeship, domestic content, energy community
• 10‑year window tracker with a checkbox for each tax year claimed

The Documentation Vault

• Registration numbers for elective pay or transfer, if applicable
• Contracts, invoices, and proof of costs if you used the 5% safe harbor
• Manufacturer or supplier domestic content statements
• Maps or listings that prove energy community status, saved as PDFs
• Payroll records, certified payrolls, apprenticeship agreements, and cure memos
• Revenue‑grade meter reads and settlement statements, monthly to annual

The Production Tie‑Out

Reconcile monthly kWh to annual totals, then to revenue. Exclude station use and unsold generation. Document curtailments, outages, and any meter replacements. If multiple facilities feed one revenue stream, include a worksheet splitting totals by meter and facility.

IRA Impacts, Simplified

Wage and apprenticeship can elevate you from a reduced base amount to the full historical level for eligible projects. If your facility is over 1 MW and placed in service after 2021, this matters. Put a single page in the file listing which contractors were on site, the wage determinations you applied, apprenticeship ratios, total apprentice hours, and any corrections paid with interest if you had to cure a shortfall.

Domestic content and energy community each add a 10% adder to the computed credit for eligible facilities (note: domestic content qualification under section 45(b)(9) is determined once at placed-in-service and locks in for the full 10-year credit period, while energy community status under section 45(b)(11) must be re-verified each tax year you claim the bonus). Your file needs more than a checked box. For domestic content, include component lists, part numbers, and manufacturer attestations. For energy community, include the facility location overlayed on a qualifying tract or listing, plus a short narrative that explains the criteria.

Finally, remember that the tech‑neutral path, Section 45Y, starts for facilities placed in service after December 31, 2024. If you have a 2025 in‑service project that meets 45Y, you will use the clean electricity form for that facility, while still filing Form 8835 for legacy Section 45 projects in their remaining years. It is normal to have both in the same return period.

A Quick Story From Review

A partner sent me a geothermal file with twelve months of meter data and a perfect total, yet the credit was off by 8 percent. The issue was subtle. Two months of station power had been included in “sales,” and the settlement statements showed a net kWh amount that was lower than the raw reads. Once we reconciled to settlement, the credit number fell into place, and the IRS notice never came. Your best friend is a three‑column tie‑out that shows meter reads, settlement, and the final “kWh produced and sold” number you put on the form.

Eligible Energy Resources, Explained Simply

You qualify for the Section 45 production credit when you produce and sell electricity from a listed resource and your facility meets the timing and documentation rules. In practice, most filers on Form 8835 fall into these buckets:

• Wind, both utility‑scale and community‑scale
• Closed‑loop biomass and geothermal
• Open‑loop biomass, landfill gas, and trash
• Qualified hydropower, marine, and hydrokinetic
• Solar in the IRA reinstatement window that still files under Section 45

Two steps keep you out of trouble. First, match your facility to an enumerated resource in the instructions. Second, pin down the placed‑in‑service date and the year of production. The rate comes from those two facts, not from industry chatter or a spreadsheet you used last year.

Base amounts, multipliers, and adders

Think about the math in layers, so you never miss a step.

• Resource base, by kWh, based on vintage and resource type.
• Wage and apprenticeship multiplier, which can elevate you from a reduced base to the full historical level when you meet the rules.
• Adders for domestic content and energy community, typically 10 percent each, stacked after you compute the main credit.
• Facility clock, which runs for 10 tax years from the placed‑in‑service date.

Document each layer in your workpapers, then place the figures on the correct lines in Part II.

What Changed In 2023, And What Matters Now In 2025

The 2023 revision of Form 8835 did three things that still shape how you file now.

• The title shifted to “Renewable Electricity Production Credit,” which mirrors the Section 45 focus many filers already use.
• The form added explicit space to indicate wage and apprenticeship, domestic content, and energy community, so you do not bury these in a memo.
• The IRS clarified how to present adjustments and facility‑level information, which raised the bar on documentation.

What does that mean for you in 2025?

• Keep using Form 8835 for Section 45 facilities that are still inside their 10‑year window.
• If a facility placed in service after December 31, 2024 qualifies under the tech‑neutral clean electricity regime, follow the clean electricity form for that facility and year, while keeping 8835 for legacy 45 projects.
• Expect the instructions to remain the primary source for annual rates, definitions, and line references, and build your process around that document.

If you are unsure whether a 2025 placed‑in‑service site belongs on Form 8835 or a clean‑electricity form, decide before you start workpapers. Moving later means rebuilding all your tie‑outs.

Construction Start And Placed‑In‑Service, The Two Dates That Decide Everything

You only need two milestones to control 90 percent of your compliance. Get them right, then backfill the support.

Beginning of construction

You started construction when either physical work of a significant nature began, or you incurred at least 5 percent of total project cost under the safe harbor. Document the method you used and your continuity path. Keep a short, dated memo that answers four questions:

• Which method did you use, and why.
• What evidence proves it, invoices or on‑site work logs.
• How did you maintain continuity, continuous construction or continuous efforts.
• Who reviewed and signed off at the time, not months later.

Projects under one megawatt often get relief on wage and apprenticeship, which can change how your multiplier works. Capture capacity, do not leave it implied.

Placed in service

Placed in service is when the facility is ready and available for its assigned function. Your evidence is not a guess, it is a bundle: commercial operation date notice, interconnection documents, permission to operate, and the date the asset was moved from construction in progress to a depreciable asset on the fixed asset ledger. Put the date on the master sheet for the facility and use it to start your 10‑year clock. If you have multiple units, track each unit separately, then roll up as needed.

Why dates tie directly to dollars

• The placed‑in‑service year decides which tax return carries the first Form 8835.
• The 10‑year production window flows from that date, so your carryforwards and annual ticklers hang from this single milestone.
• Your wage and apprenticeship posture can hinge on the capacity and timing, so steady documentation helps preserve the higher rate.

Quick Checklist Before You Touch The Form

• Facility master sheet created and reviewed.
• Beginning‑of‑construction memo and evidence filed.
• Placed‑in‑service evidence bundle compiled.
• Revenue‑grade meter data reconciled to settlement statements.
• Station use and curtailments excluded, with a note.
• Wage and apprenticeship summary sheet updated, including cure steps if any.
• Domestic content packet assembled, part lists and manufacturer attestations included.
• Energy community map and tract IDs saved as PDFs.
• 10‑year window tracker updated, including prior year filings and carryforwards.

Once these items are ready, opening Form 8835 is the easy part.

The Information You Must Gather To Complete Form 8835

Treat the form as the last step. The real work is collecting precise identifiers and clean numbers.

• Taxpayer identifiers, legal names, EINs, return type
• Facility name, registration or internal ID, resource type
• Physical address and coordinates, plus interconnection details
• Beginning‑of‑construction method and date, with continuity notes
• Placed‑in‑service date tied to asset accounting and COD evidence
• Annual kWh produced and sold, by facility and by month
• Status of wage and apprenticeship, domestic content, energy community
• Ownership percentages as of year end, and allocation method for pass‑throughs

Workpaper structure that wins reviews

Create a standard folder set for every facility:

• 00 Master sheet and facility summary
• 10 Dates, BOC and PIS evidence
• 20 Production, meters and settlements, monthly to annual
• 30 Wage and apprenticeship, payroll and apprenticeship agreements
• 40 Domestic content, component lists and certifications
• 50 Energy community, maps and tract IDs
• 60 Ownership and allocations, cap table and K‑1 tie‑outs
• 70 Forms, filled PDFs and e‑file packages

This hierarchy keeps your team aligned and helps a reviewer find answers in seconds, not hours.

Step‑By‑Step, How To Complete The Core Lines

• Part I, Lines 1 to 4, enter the legal name, identifying number, facility name, registration if issued, resource type, and complete location. Insert both street address and coordinates if you have them, since coordinates make mapping and energy community verification easy later.
• Construction and placed‑in‑service dates, place them exactly as your evidence states. If a unitized project has multiple placed‑in‑service dates, file per facility template and footnote any unit breakdowns in your workpapers.
• Part II, Lines 5 to 7, report total kWh produced and sold for the tax year. Use the rate from the instructions that matches your facility’s resource and vintage. Multiply to compute the base credit.
• Line for wage and apprenticeship, indicate compliance status, and document the multiplier in your workpapers.
• Line for domestic content and energy community, check the boxes only if your file includes the certifications and maps.
• Total and carry, then follow the instructions to place the credit on the correct line of your business return. For pass‑throughs, prepare the K‑1 disclosures and attach any statements that your software supports as PDFs.

The feelings table we share with new reviewers

Step	Feeling	Result
Accuracy	Relief	Clean audit trail
Completeness	Confidence	Full credit capture
Documentation	Assurance	Defensible claim

If your reviewer cannot re‑create your math and decisions in five minutes, the IRS will not be able to either. Aim for instant clarity.

Production Data, The Heart Of The Credit

• Use revenue‑grade meters and settlement statements as your source of truth.
• Reconcile month by month, then tie to the annual total.
• Exclude station use, unsold generation, and line losses not reflected in sold kWh.
• If two facilities roll to one settlement, break it out by meter, then summarize back to the form.
• Save a one‑page production summary that shows the monthly totals, the annual sum, and the exact number you entered on Form 8835.

Small habit, big payoff. This single sheet answers most reviewer questions.

Ownership And Allocation, Without The Headaches

For partnerships and S corporations, compute the facility credit first, apply wage and apprenticeship and any adders at the facility level, then split the total by ownership percentage as of year end or by the agreed method in your documents. Partnerships and S corps stop at Form 8835 line 15 and report on Schedule K – they do not carry the credit to Form 3800; owners claim it on their own Form 3800. Cooperatives, estates, and trusts continue past line 15 to lines 16 and 17 to allocate to patrons or beneficiaries before any Form 3800 reporting. Include a short allocation memo when ownership changes during the year, so the K‑1 team is not guessing. If you transfer credits or use elective pay, attach the registration numbers and follow your software’s attachment protocol so the return is complete the first time.

Wage And Apprenticeship, The Multiplier You Cannot Ignore

If your facility is over one megawatt (measured in alternating current per Form 8835 line 8a, not DC nameplate, which matters for solar where DC capacity can substantially exceed AC output) and placed in service after 2021, you only reach the higher production credit level when you satisfy prevailing wage and registered apprenticeship. This is not a check‑the‑box issue, it is a process.

• Determine applicable wage determinations for the location and job classifications.
• Include the requirement in contracts for contractors and subcontractors.
• Track apprentice hours and ratios, and maintain signed apprenticeship agreements.
• Perform periodic payroll reviews and correct any underpayments promptly, with interest and documented cures.
• Keep records by facility and date ranges, since these rules apply during construction and certain post‑placement maintenance.

A one‑page compliance summary in every facility file turns a difficult review into a quick confirmation.

Domestic Content And Energy Community Bonuses

Two adders, each typically 10 percent, can lift your total credit for eligible facilities. The time you invest here pays back immediately at filing.

Domestic content, what to keep

• A component‑level parts list with manufacturer names, part numbers, and country of origin.
• Supplier or manufacturer certifications that the steel, iron, and manufactured products meet the thresholds.
• A short calculation that shows how you concluded the threshold is met, saved as a PDF.
• The affirmative statement you will attach with the return.

Energy community, how to prove location

• The project address and coordinates, saved on the master sheet.
• A map or listing that shows the facility sits in a qualifying census tract or listed area.
• A short narrative, a few sentences, that names the tract and the criterion met, for example a former coal facility tract.
• Keep the map as a dated PDF in your file, not just a screenshot in a slide deck.

Common pitfalls

• Claiming domestic content with only a marketing brochure.
• Checking energy community without tract evidence.
• Forgetting to attach the required statements to the return.
• Relying on vendor emails that do not identify part numbers or origin.

Documentation Requirements, A Short Playbook

• Production packet, meters, settlements, monthly to annual reconciliation.
• Dates packet, beginning‑of‑construction memo and placed‑in‑service bundle.
• Wage and apprenticeship packet, determinations, agreements, payrolls, cures.
• Domestic content packet, component lists and certifications.
• Energy community packet, maps, tract IDs, and narrative.
• Ownership and allocation packet, cap table, agreements, and K‑1 tie‑out.
• Prior year Form 8835, credit carryforward tracker, and any IRS correspondence.

When an IRS notice arrives, your packets become your defense. Build them while the facts are fresh, not during an appeal.

Quality Control, Borrowed From Production Review

Borrow what works from your month‑end close:

• A preparer completes the file, a senior reviews, and a manager signs off.
• A simple checklist covers the form lines and the attachments.
• A naming convention keeps files easy to scan, for example, “2025‑FAC1‑DomesticContent.pdf.”
• A calendar tickler flags the remaining years in the 10‑year window and the return due date, including extensions.

If your firm has seasonal spikes, treat Form 8835 like a mini close, with the same cadence and controls.

Filing, Attachments, And Timing

Attach Form 8835 to the federal return for the tax year in which the electricity was produced and sold. Include all required statements for wage and apprenticeship, domestic content, and energy community when you claim them. If you are a pass‑through, complete the K‑1 disclosures so owners receive their share. If you use elective pay or transfer, include the registration data and any software attachment required by your e‑file provider. Keep paper copies of the evidence packets for the statute period.

Deadlines and practical timing

• Confirm beginning‑of‑construction and placed‑in‑service dates early, they control eligibility and the 10‑year window.
• Reconcile production data monthly, then finalize the annual tie‑out before trial balance close.
• Review wage and apprenticeship, domestic content, and energy community evidence before year end, not in March.
• If you must amend, do it with a complete packet, not a single page.

Where Accountably Fits, Briefly

If you are a CPA or accounting leader who needs Form 8835 handled with the same discipline as month‑end close, Accountably can provide structured offshore delivery that plugs into your workflow. Our teams work inside your systems, follow your templates, and keep the documentation packets, naming conventions, and review checklists tight. That way, partners spend less time in review, and your Form 8835 files move with predictability. Use us only where it adds value, for example, annual production tie‑outs and evidence packet assembly.

Conclusion

Form 8835 is not hard when you treat it like a process. Identify the resource, lock down the two decisive dates, reconcile kWh to sales, and collect the evidence for wage and apprenticeship, domestic content, and energy community. File once per facility, track your 10‑year window, and keep the packets current. Do this well, and you turn Form 8835 from a scramble into a predictable part of your compliance calendar.

Common Mistakes We See Every Season

Most Form 8835 cleanups we run trace back to the same handful of decision points. A rate gets assumed, a date gets conflated, a bonus gets computed against the wrong base, and the credit comes out wrong by tens or hundreds of thousands.

Reusable Checklists

Each checklist below is copy-paste ready for an SOP folder. Adapt the line items to match the resource mix on the engagement.

Keep 8835 Season From Stalling

Form 8835 work is unusual inside a tax practice: it is annual, but every annual filing depends on facility data that was first captured years earlier at placed-in-service. The 10-year credit period under Section 45 means the same project comes back to the desk every season for a decade, with new kWh data, a re-verified energy community status, and the same begin-construction and placed-in-service dates that have to stay consistent across every year of the window, per the Form 8835 instructions on IRS.gov.

The pattern that stalls is treating each year as a fresh return instead of a recurring engagement on a known facility. The fix is to build the facility binder once at intake and pull from it on every subsequent line 1 through line 13 entry.

• Maintain a per-facility binder with placed-in-service date, begin-construction date, nameplate AC, latitude and longitude (with sign), IRS registration number, and resource type. Reuse it on every annual line 3 through line 5 entry for the 10-year credit window.
• Lock the kWh-sold reconciliation against meter data and the unrelated-buyer invoice trail before any line 1 column (a) entry is recorded.
• Re-test energy community status each tax year for the line 11 bonus; do not carry the prior-year designation forward.
• Run the qualified-facility check (1 MW AC safe harbor, January 29, 2023 grandfather, or Section 45(b)(7) and 45(b)(8) compliance) before applying the 5x multiplier on line 9.
• Track whether the engagement year falls inside the first 4 years (Form 3800 Part III line 4e) or years 5 through 10 (Form 3800 Part III line 1f) for the same credit.

This is the production discipline behind clean Form 8835 returns: standing facility binders, an annual reconciliation pack, and a re-test calendar that fires on schedule. Accountably's tax delivery teams run this structure across renewable-energy engagements so the work scales without the season-over-season scramble.

FAQs

What is Form 8835 used for, in plain terms?

You use Form 8835 to claim the Section 45 Renewable Electricity Production Credit on electricity you produce and sell from a qualified facility. You report facility details, the key dates, and kWh sold, then indicate wage and apprenticeship, domestic content, and energy community if you qualify.

Is clean hydrogen under Section 45V filed on Form 8835?

No. Section 45V has its own form. Keep 8835 focused on the renewable electricity production credit, and follow the current IRS form for clean hydrogen in the year you file.

What about clean electricity under Section 45Y in 2025?

Facilities placed in service after December 31, 2024 that meet 45Y follow the tech‑neutral clean electricity form for that year. You may have both, 8835 for legacy 45 projects still in their 10‑year window and the clean electricity form for new projects.

Do I have to meet wage and apprenticeship to claim any credit?

You can claim a reduced base amount without wage and apprenticeship in many cases, but projects over one megawatt placed in service after 2021 generally need wage and apprenticeship to reach the higher level. Keep payroll and apprenticeship documentation to support your position.

What records should I keep for domestic content and energy community?

For domestic content, keep manufacturer certifications and a component‑level list that shows country of origin. For energy community, keep a dated map or official listing for the qualifying tract, plus a short narrative. Attach the required statements when you claim the adders.

How do I split credits among owners in a partnership?

Compute the facility‑level credit, apply any multipliers and adders, then allocate by ownership as of year end or by your agreement. Reconcile those amounts to K‑1s, and keep a simple memo that explains the method if ownership changed during the year.