Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases and Partnership Flips

Choosing the Right Structure, Weighing Advantages and Drawbacks of Various Structures

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

Conducted on Thursday, November 29, 2018

Recorded event now available

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Program Materials

This CLE webinar will discuss solar financing tax equity structures—sale-leasebacks, inverted leases and partnership flips—and the advantages and disadvantages of each from a legal, business, financial and tax perspective. The panel will examine current trends and issues in solar financings.


There are three main tax equity structures in use currently for financing solar energy deals: sale-leasebacks, inverted leases and partnership flips. There are also a number of variations on these basic structures.

Listen as our authoritative panel discusses the pros and cons of sale-leasebacks, inverted leases, and partnership-flip tax-equity structures. They will explain the legal, business, financial and tax reasons driving the choice of structure and will discuss trends in solar financing as well as the investment tax credit.



  1. Current state of the solar finance market and trends for the near future
  2. Choosing the appropriate tax equity structure
    1. Sale-leaseback
    2. Inverted lease
    3. Partnership flip
  3. Evaluating the tax risks
  4. Current issues in deals


The panel will review these and other noteworthy issues:

  • When to choose one structure over another.
  • What are the main issues on which the parties spend the most time in negotiations?
  • How are the Alta and California Ridge cases affecting how deals are structured?
  • What is current market on such things as construction-start strategies, developer fees, basis step ups, change-in-law risk, flip yields, DROs, tax insurance, unwinds and withdrawal rights?


Martin, Keith
Keith Martin

Norton Rose Fulbright US

Mr. Martin is a transactional lawyer whose principal areas of practice are tax and project finance. He acted for 178...  |  Read More

Jorge Medina
Jorge Medina
Associate General Counsel, Tax

Mr. Medina is primarily responsible for all tax issues across Tesla that relate to the energy and storage business. He...  |  Read More

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