Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases, and Partnership Flips
Choosing the Right Structure, Weighing Advantages and Drawbacks of Various Structures
Note: CPE credit is not offered on this program
Recording of a 90-minute premium CLE webinar with Q&A
This CLE course 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.
Outline
- Current state of the solar finance market and trends for the near future
- Choosing the appropriate tax equity structure
- Sale-leaseback
- Inverted lease
- Partnership flip
- Evaluating the tax risks
- Current issues in deals
Benefits
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 Bishop Hill and California Ridge cases impacting how deals are structured?
- What is the 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?
Faculty
Jorge Medina
Partner
Pillsbury Winthrop Shaw Pittman
Mr. Medina’s practice focuses on tax aspects of energy investment and financing transactions, including tax... | Read More
Mr. Medina’s practice focuses on tax aspects of energy investment and financing transactions, including tax equity investments in the renewables space. He regularly works on federal tax policy and controversy issues involving renewable energy, and he has extensive experience structuring tax-driven transactions. Prior to joining the firm, Mr. Medina was associate general counsel-tax at automotive and energy company Tesla Inc. He was primarily responsible for all tax issues across Tesla related to the energy and storage business. Mr. Medina previously served as Vice President and Deputy General Counsel at SolarCity, which Tesla purchased in 2016. He also previously worked at Dewey LeBoeuf and Sidley Austin, where he handled a wide range of U.S. tax matters, particularly those in the renewable energy, equipment leasing, and tax equity fields.
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Keith Martin
Co-Head of Projects
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
Mr. Martin is a transactional lawyer whose principal areas of practice are tax and project finance. He acted for 178 companies last year and worked on transactions in the United States and eight foreign countries. He also lobbies Congress and the Treasury Department on policy issues. He is co-head of the Firm’s project finance group.
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