The tax equity entities were structured at inception so that the allocations of income and loss for tax purposes will flip at a future date. The terms of the tax equity entities’ operating agreements contain allocations of taxable income (loss), Section 48(a) ITCs and cash distributions that vary over time and adjust between the members on an agreed date (referred to as the flip date). The operating agreements specify either a date certain flip date or an internal rate of return (“IRR”) flip date. The date certain flip date is based on the passage of a fixed period of time as defined in the operating agreements for each entity. The IRR flip date is the date on which the tax equity investor has achieved a contractual rate of return. From inception through the flip date, the Class A members' allocation of taxable income (loss) and Section 48(a) ITCs is generally 99% and the Class B members' allocation of taxable income (loss) and Section 48(a) ITCs is generally 1%. After the related flip date (or, if the tax equity investor has a deficit capital account, typically after such deficit has been eliminated), the Class A members' allocation of taxable income (loss) will typically decrease to 5% (or, in some cases, a higher percentage if required by the tax equity investor) and the Class B members' allocation of taxable income (loss) will increase by an inverse amount. As of March 31, 2025, the allocations of income and loss for tax purposes had flipped for ORE F4 Holdco, LLC. Volta Solar Owner II, LLC has not reached its flip date.

The Company’s historical noncontrolling interests are comprised of Class A units, which represent the tax equity investors' interest in the tax equity entities. Both the Class A members and Class B members may have call options to allow either member to redeem the other member's interest in the tax equity entities upon the occurrence of certain contingent events, such as bankruptcy, dissolution/liquidation and forced divestitures of the tax equity entities. Additionally, the Class B member in Volta Solar Owner II, LLC has the option of purchasing all Class A units, which is exercisable at any time during the periods specified under its respective governing document.

The assets held by the Company’s VIEs can only be used to settle obligations of the VIEs, while the liabilities are the obligations of the Company’s VIEs. The following table summarizes the consolidated balance sheets of the Company’s VIEs included within assets and liabilities on the Company’s unaudited condensed consolidated balance sheets as of March 31, 2025 and December 31, 2024:


	As of
(In thousands)	March 31, 2025		December 31, 2024
Assets
Current assets

Restricted cash	$	692	$	1,375
Accounts receivable	718		525


Accounts receivable - affiliates	77		100
Prepaid expenses and other current assets	2		105

Total current assets	1,489		2,105

Property and equipment, net	34,493		34,950


Intangible assets, net	96		91




Total assets	$	36,078	$	37,146
Liabilities
Current liabilities


Accounts payable - affiliates	$	1,292	$	1,178
Deferred revenue, current	59		52

Accrued expenses and other current liabilities	143		472


Total current liabilities	1,494		1,702

Deferred revenue, non-current	122		133




Unfavorable solar renewable energy agreements, net	153		188

Total liabilities	$	1,769	$	2,023