In this case it's an institute attached to a big university (University of Texas) that is scaling up an R&D idea, that happens to be useful for the military https://www.statesman.com/story/business/2024/07/18/semicond...

Which is effectively the same thing that happens even with non-refundable credits for large conglomerates, because they were paying enough in taxes from their other business units to eat the whole thing, while they're still consuming other government services. In order to make that fair to smaller companies and individuals, someone with a non-refundable credit that they couldn't use should be able to sell it to an unrelated business who could use it. But then it would just sell for approximately its face value and affect the government budget in exactly the same amount as if it was a refundable credit, which is why tax credits should always be refundable.