v3.26.1
Income Taxes
6 Months Ended
Jun. 30, 2026
Income Tax Disclosure [Abstract]  
Income Taxes
16.
INCOME TAXES

The effective tax rate for the three months ended June 30, 2026 and 2025 was 0.55% and (0.14%), respectively. The effective tax rate for the six months ended June 30, 2026 and 2025 was (0.22%) and (0.12%), respectively.

The Company's effective tax rate differs from the U.S. federal statutory rate primarily because the Company generated a loss for federal income tax purposes during the period, resulting in no current federal income tax expense. In addition, the Company maintains a full valuation allowance against its deferred tax assets, resulting in no federal tax benefit being recognized on the loss. Accordingly, the effective tax rate is primarily driven by Texas margin tax expense, which is determined under a tax base that is not directly related to taxable income.

Tax Receivable Agreement

Concurrently with the closing of the IPO, the Company entered into the Tax Receivable Agreement (the “TRA”) with certain Continuing Equity Unitholders, certain Continuing Profits Interest Unitholders and certain entities interposed between certain pre-IPO owners that received shares of the Company’s Class A common stock pursuant to mergers consummated in connection with the IPO pursuant to which each company first became a wholly owned subsidiary of the Company and then merged into the Company (including Energy Impact Fund (FT-B) LP) (together, the “TRA Beneficiaries”) and a designated TRA representative. The TRA provides for payment by us to the TRA Beneficiaries of 85% of the amount of the net cash tax savings, if any, that the Company actually realizes or are deemed to realize (calculated using certain assumptions) as a result of the Company’s use of certain tax benefits resulting from (i) certain increases in, or adjustments to, the tax basis of assets of ER Holdings and its subsidiaries resulting from exchanges of ER Holdings membership interests in the future, (ii) certain tax attributes available to the Company as a result of the Reorganization, and (iii) certain other tax benefits related to the Company’s entering into the TRA, including tax benefits attributable to payments that the Company makes under the TRA. The Company will retain the remaining 15% of such amount of the net cash tax savings. The actual future payments to the TRA Beneficiaries will vary based on a number of factors including the timing and amount of the Company’s future income.

The Company accounts for amounts payable under the TRA in accordance with ASC Topic 450, Contingencies. As such, subsequent changes in the value of the tax receivable agreement liability between reporting periods are recognized in the unaudited condensed consolidated statements of operations.

One Big Beautiful Bill Act

On July 4, 2025, the One Big Beautiful Bill Act (the “Act”) was enacted in the U.S. The Act includes significant provisions, such as the permanent extension of certain expiring provisions of the Tax Cuts and Jobs Act, modifications to the international tax framework and the restoration of favorable tax treatment for certain business provisions.

The Act has multiple effective dates, with certain provisions effective in 2025 and others implemented through 2027. These include changes in bonus depreciation on fixed assets and changes to the deductibility of section 174 (research and development) expenses. Currently there is no significant impact of the Act on the unaudited condensed consolidated financial statements.