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

A live 90-minute premium CLE video webinar with interactive Q&A

Tuesday, November 30, 2021

1:00pm-2:30pm EST, 10:00am-11:30am PST

Early Registration Discount Deadline, Friday, November 5, 2021

or call 1-800-926-7926

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 financing.


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.

The U.S. Court of Federal Claims in the companion cases of Bishop Hill Energy L.L.C. and California Ridge Wind Energy L.L.C., found in favor of the government and denied a Section 1603 grant reimbursement for the taxpayer, a renewable energy developer. The court held that developer fees are included on a cost basis and eligible for the Section 1603 grant. Still, it was not convinced that there was adequate substantiation of developer fees in these cases.

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 discuss trends in solar financing and 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 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?


Medina, Jorge
Jorge Medina

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

Attend on November 30

Early Discount (through 11/05/21)

Cannot Attend November 30?

Early Discount (through 11/05/21)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video