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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Energy

Date & Time
  • event Date

    Tuesday, May 10, 2022

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00

This CLE/CPE webinar will provide renewable energy counsel guidance on the legal and tax challenges for foreign investors in U.S. renewable energy projects. The panel will discuss deal structures and key provisions, applicable U.S. tax law and IRS regulations impacting foreign investors, legal requirements, and processes to maximize benefits and limit liability. The panel will also provide insights on other key legal considerations and planning strategies for foreign investors associated with U.S. renewable energy development and financing.

Faculty

Moronne Almira
Shareholder
Davis Graham & Stubbs LLP

Ms. Moronne's practice focuses on mining and foreign investment transactions and natural resources development on public and private lands. She represents junior, mid-level and senior mining companies at all stages of project development, as well as the investors and lenders that finance mining projects through traditional equity, lending, royalty, and streaming arrangements. Ms. Moronne also works with clients in a wide range of industries in cross-border transactions and joint ventures, with expertise in navigating the national security screening process under the Committee on Foreign Investment in the United States (CFIUS).

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Grappone Tony
Shareholder
Novogradac & Company, LLP

Mr. Grappone specializes in providing accounting, tax and consulting services to developers, syndicators and investors of developments that qualify for federal and state tax credits such as the low-income housing tax credit, historic rehabilitation tax credit, new markets tax credit, renewable energy tax credits and opportunity zone incentives. He is a frequent speaker at various renewable energy and other tax credit industry events and has contributed several articles on renewable energy to the Novogradac Journal of Tax Credits and serves as a technical editor of the Novogradac Renewable Energy Tax Credit Handbook.

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Description

The U.S. has been increasing in popularity as a destination for foreign capital investments in U.S. renewable energy projects. Critical for attorneys representing U.S. renewable energy projects or non-U.S. persons investing in U.S. renewable energy projects and related entities, is a complete understanding of optimal structures for the ownership vehicle and the mechanics of the transaction itself.

Energy counsel must have a complete understanding of various opportunities and pitfalls in structuring the investment transaction, such as 1.) utilizing special purpose vehicles (SPV) for renewable energy projects; 2.) key issues when accepting foreign investors; 3.) income and transfer tax implications; 4.) exit strategy issues relating to foreign investors; 5.) compliance and reporting requirements; and other key items.

Listen as our panel of renewable energy attorneys goes beyond the basics to provide a comprehensive and practical guide to structuring foreign investment in U.S. renewable energy project development.

Outline

  1. Structuring SPVs for energy projects
  2. Applicable rules and key considerations for foreign investors
  3. Investment structure alternatives
  4. Tax implications

Benefits

The panel will review these and other key issues:

  • What are the key considerations in structuring investments in renewable energy projects?
  • What are the potential legal and tax implications for foreign investors?
  • What is the impact of blocker corporations and other intermediary entities on the tax treatment of foreign investment in U.S. renewable energy?
  • What methods are available to counsel to ensure compliance with U.S. and foreign reporting requirements?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify various ownership structures and related tax consequences for foreign investors in U.S. renewable energy
  • Determine the optimal purchasing entity for a foreign investor in U.S. renewable energy projects
  • Ascertain tax planning opportunities in structuring a deal involving foreign investment in U.S. business entities

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).