Can I apply the cost of a new roof to my Investment Tax Credit (ITC)?

Typically no, but it has been done. Roof improvement costs can be included in instances where the roof updates are required for the solar system to reach the maximum power generation.

One example is the use of bi-facial panels (which produce power from both sides) requiring a white roof. We have heard that developers have made the case for including these costs in the total project costs. 

When evaluating the costs of a project as they relate to the ITC, you will want to engage a tax lawyer who specializes in Investment Tax Credits. The IRS has not released comprehensive guidance for the new ITC provisions outlined by the Inflation Reduction Act 2022, so be sure to engage a tax lawyer who is in tune with the roll-out of this guidance.