Tax Equity & Structure

What Sets Us Apart

We structure traditional and IRA-era tax equity, transfer, and safe harbor transactions, helping clients monetize the ITC, PTC, and other credits while navigating Prevailing Wage, Domestic Content, FEOC and evolving IRS guidance.

Areas of Expertise

  • Partnership flips, sale-leasebacks, and lease pass-through (inverted lease) structures

  • Straight and hybrid tax credit transfer structures, including T-Flips

  • Elective/direct pay and basis step-up transactions

  • Prevailing Wage and Apprenticeship (PWA) and Domestic Content compliance

  • 45X, 45W, 48E, 30C, 45Q, and other IRA tax credit qualification

  • Safe harbor equipment purchasing and tax credit eligibility strategy

  • Comprehensive tax due diligence, estoppels, and consents

  • Tax opinion support for credit adders (domestic content, energy communities, LMI)

  • Tribal tax credit structuring

  • Corporate and transaction tax structuring

Key Contacts

Zach Crowley

Partner

Sandra Lee

Partner

Representative Transactions

  • Counseled a tax equity investor in its $280 million investment in a portfolio of over 30 community solar projects across the United States.

  • Lead transaction counsel for a national utility-scale developer in its $248 million sale-leaseback tax equity transaction with a major investment bank.

  • Acted as lead transaction counsel to a national developer in its $70 million hybrid tax credit transfer structure for the sale of investment tax credits generated by a portfolio of solar projects in Maine, Maryland, Illinois, and Virginia.

  • Acted as lead counsel to a national community solar developer in its transfer of $135 million in investment tax credits to two leading tax credit syndicators, including tax opinions for domestic content and LMI adders.

  • Represented tax equity investor in its $185.6 million investment in three retrofitted wind projects in Texas with an aggregate nameplate capacity of 546 MW.

  • Represented two tax equity investors in an aggregate $246.7 million investment in three retrofitted wind projects in Texas totaling 449 MW.

  • Advised a leading international bank in its $70 million tax equity investment in a portfolio of three utility-scale solar projects in Texas, Colorado, and Vermont.

  • Represented Tribal Energy umbrella organization in equipment safe harbor and tax credit structuring matters.

  • Provided a tax opinion on qualification for the 45X tax credit ahead of transfer of the credit to a US-based solar equipment manufacturer.

  • Assisted a leading Massachusetts natural gas producer with evidencing 45Q carbon sequestration credit eligibility.

  • Represented an electric auto manufacturer in the sale of certain 30C federal tax credits generated by EV charging stations in California and Texas.