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Foreign Investment in U.S. Renewable Energy Projects: Deal Structures, Tax Issues, Accumulating Assets, Capitalization

Recording of a 90-minute premium CLE/CPE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
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Conducted on Tuesday, May 10, 2022

Recorded event now available

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This CLE/CPE webinar will provide renewable energy counsel guidance on the legal and tax challenges for foreign investors in U.S. renewable energy projects. The panel will discuss deal structures and key provisions, applicable U.S. tax law and IRS regulations impacting foreign investors, legal requirements, and processes to maximize benefits and limit liability. The panel will also provide insights on other key legal considerations and planning strategies for foreign investors associated with U.S. renewable energy development and financing.


The U.S. has been increasing in popularity as a destination for foreign capital investments in U.S. renewable energy projects. Critical for attorneys representing U.S. renewable energy projects or non-U.S. persons investing in U.S. renewable energy projects and related entities, is a complete understanding of optimal structures for the ownership vehicle and the mechanics of the transaction itself.

Energy counsel must have a complete understanding of various opportunities and pitfalls in structuring the investment transaction, such as 1.) utilizing special purpose vehicles (SPV) for renewable energy projects; 2.) key issues when accepting foreign investors; 3.) income and transfer tax implications; 4.) exit strategy issues relating to foreign investors; 5.) compliance and reporting requirements; and other key items.

Listen as our panel of renewable energy attorneys goes beyond the basics to provide a comprehensive and practical guide to structuring foreign investment in U.S. renewable energy project development.



  1. Structuring SPVs for energy projects
  2. Applicable rules and key considerations for foreign investors
  3. Investment structure alternatives
  4. Tax implications


The panel will review these and other key issues:

  • What are the key considerations in structuring investments in renewable energy projects?
  • What are the potential legal and tax implications for foreign investors?
  • What is the impact of blocker corporations and other intermediary entities on the tax treatment of foreign investment in U.S. renewable energy?
  • What methods are available to counsel to ensure compliance with U.S. and foreign reporting requirements?


Grappone, Tony
Tony Grappone, CPA

Novogradac & Company

Mr. Grappone specializes in providing accounting, tax and consulting services to developers, syndicators and investors...  |  Read More

Moronne, Almira
Almira Moronne

Davis Graham & Stubbs

Ms. Moronne's practice focuses on mining and foreign investment transactions and natural resources development on...  |  Read More

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