Interesting that section 45T does not include the requirement that there be at least one NHCE the way section 45E does.
My reading of section 45T and Pub 560 is that the the credit for a particular taxable year (that which can be claimed on a particular tax return) is $500. It wouldn't makes sense to allow the credit with respect to 2026 or 2027 because in 2025 it cannot yet have been established that the arrangement was maintained for 2026 and 2027. Assuming that your plan maintains the arrangement for three years, you would claim a credit of $500 on your 2025 tax return, $500 on your 2026 tax return and $500 on your 2027 tax return.
