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 video webinar with Q&A

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Conducted on Tuesday, November 30, 2021

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Course Materials

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 financing.

Description

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

Supply-chain difficulties and potential changes in tax law are forcing some changes in deal papers. Congress is debating restoring clean energy tax credits to their full level and also imposing several paragraphs of fine print in the form of wage, apprentice and domestic content requirements. It may also allow companies to receive direct cash payments in place of tax credits.

Listen as our authoritative panel discusses the pros and cons of the various structures, how the tax proposals currently under debate in Congress are being addressed in deals and other current issues.

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Outline

  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

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?
  • 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

Medina, Jorge
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

Martin, Keith
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

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