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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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, November 1, 2023

Recorded event now available

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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.


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 current tax law are forcing some changes in deal papers. Congress has restored and added clean energy tax credits and other incentives to their full level and also imposed several paragraphs of fine print in the form of wage, apprentice, and domestic content requirements.

Listen as our authoritative panel discusses the pros and cons of the various structures and the impact of recent regulations on deals and other current issues.



  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?
  • 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?


Jacques, Gabrielle
Gabrielle Jacques

Senior Associate
Norton Rose Fulbright

Ms. Jacques is a senior associate in Norton Rose Fulbright's New York office. Gabrielle's practice...  |  Read More

Lefko, Hilary
Hilary Lefko

Norton Rose Fulbright US

Ms. Lefko focuses her practice on all areas of federal income tax law, with a particular emphasis on tax...  |  Read More

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