Tax Ramifications of Public-Private Partnerships in Infrastructure Projects

Tax Planning Strategies to Maximize Profits in PPP Deals

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

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Conducted on Thursday, December 10, 2009

Recorded event now available

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Course Materials

This CLE seminar will analyze the critical tax planning strategies for structuring public-private partnerships (PPPs), including the federal tax treatment for brownfield versus greenfield projects and state and local tax planning issues.


Public-private partnership (PPP) financing of infrastructure projects is now a multi-billion-dollar market. Lack of government funding coupled with the country's infrastructure crisis has created a tremendous sense of urgency for the completion of infrastructure projects.

The stimulus bill and the administration's focus on the infrastructure crisis has brought this issue to the forefront. Funding alternatives, such as PPPs, will continue to fill the financing gap.

However, there are unique and highly complex tax consequences of PPP deals that must be considered prior to the bidding process. It is essential to consider the tax attributes of various concession structures at the onset of the project. Tax practitioners must be an integral part of the planning.

Listen as our authoritative panel of tax attorneys discusses the unique federal, state and local tax consequences of PPP projects and strategies to pursue desired tax outcomes.



  1. Federal income tax treatment: brownfield and greenfield projects
    1. Typical investment structures
    2. Rights granted by state/local governments
    3. Concessionaire/developer’s obligations under lease agreement
    4. Typical financing
    5. Principal federal income tax issues
  2. State and local tax planning issues
    1. Income tax—income apportionment issues, structuring and planning
    2. Sales and use taxes
    3. Property taxes and valuation


The panel will review these and other key questions:

  • What are the differences between brownfield and greenfield infrastructure projects and how does this impact federal tax planning strategies?
  • What are tax ramifications for non-U.S. investors in PPP projects?
  • What unique state and local tax issues arise with PPP projects?


Linda E. Carlisle
Linda E. Carlisle

White Case

She practices international and domestic tax law and concentrates in the areas of taxation of corporations and...  |  Read More

R. David Wheat
R. David Wheat

Thompson & Knight

He focuses his practice on corporate tax, M&A tax, transactions involving partnerships and LLCs, and tax...  |  Read More

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