as financing of a qualified facility. (D) Taxable year in which credit taken into account In the case of any credit (or portion thereof) with respect to which an election is made under subparagraph (A), such credit shall be taken into account in the first taxable year of the eligible project partner ending with, or after, the electing taxpayer’s taxable year with respect to which the credit was determined. (E) Limitations on election (i) Time for election An election under this paragraph to transfer any portion of the credit allowed under this section shall be made not later than the due date for the return of tax for the electing taxpayer’s taxable year with respect to which the credit was determined. (ii) No further transfers No election may be made under this paragraph by a taxpayer with respect to any portion of the credit allowed under this section which has been previously transferred to such taxpayer under this paragraph. (F) Treatment of transfer under private use rules For purposes of section 141(b)(1), any benefit derived by an eligible project partner in connection with an election under this paragraph shall not be taken into account as a private business use. (G) Additional election requirements The Secretary may prescribe such regulations as may be appropriate to carry out the purposes of this paragraph, including— (i) rules for determining which persons are eligible project partners with respect to any energy property, and (ii) requiring information to be included in an election under subparagraph (A) or imposing additional reporting requirements. . (b) Energy credit (1) In general Section 48 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (e) Transfer of credit (1) In general If the taxpayer elects to transfer all (or any portion specified in the election) of the credit determined under this section for any taxable year with respect to any energy property to an eligible project partner, the eligible project partner specified in such election (and