Tax Considerations for Renewable Energy Transactions: Deal Structures, Tax Equity, Direct-Pay, and More
Analyzing Various Challenges in Structuring Transactions; Federal and State Credits; Abatements, Incentives, Recent Developments

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Energy
- event Date
Wednesday, August 31, 2022
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This CLE/CPE course will guide renewable energy counsel on key tax considerations and planning methods for renewable energy transactions. The panel will discuss federal tax issues, including claiming the investment tax credit (ITC), implications of direct pay and recent developments, depreciation and offsetting taxable income, ownership structuring issues, and other tax planning considerations.
Faculty

Ms. Mathieu advises public and private companies on a broad range of U.S. federal income tax matters, with a particular focus on both domestic and international transactions. Ms. Mathieu’s practice includes significant work involving the tax aspects of corporate mergers and acquisitions, spin-offs, and partnership transactions. She also advises clients with regard to the taxation of debt and equity financings, initial public offerings, and internal integration and restructuring transactions.

Mr. Binstock advises public and private companies on a broad range of domestic and international U.S. federal income tax issues, with particular focus on mergers, acquisitions, dispositions, joint ventures, integration and restructuring transactions, debt and equity offerings, information reporting and tax-equity financings. He has significant experience with tax issues associated with partnership taxation and renewable energy tax benefits.
Description
Renewable energy financing, development, and operations hinge on practical analysis of available tax planning techniques. Renewable energy counsel structuring projects and financing must have a complete understanding of federal income tax issues impacting the profitability of renewable energy projects.
Federal legislation incentivizes commercial and residential renewable energy investment and development with the existing ITC. Maximizing the benefits of the ITC and other tax incentives is critical to renewable energy transactions impacting an investor's desired return and exit, along with amounts to be paid to developers. Energy counsel must have in-depth knowledge of ITC requirements, the impact on tax basis, depreciation rules, and fundamental ownership structures commonly used in renewable energy transactions.
Listen as our panel discusses federal tax issues for renewable energy transactions, including claiming the ITC, potential implications of direct pay and recent developments, depreciation and offsetting taxable income, ownership structuring issues, and other tax planning considerations.
Outline
- Federal tax issues: ITC, tax basis, depreciation
- Ownership structures commonly used in renewable energy transactions
- Ownership structuring challenges: key provisions and areas for negotiation
- Implications of direct pay and recent developments
Benefits
The panel will review these and other key issues:
- What federal tax issues are present when structuring renewable energy transactions?
- What ownership structures are commonly used in renewable energy transactions?
- What are the implications of "direct pay" and recent developments?
- What are the critical considerations for counsel in light of recent legislation and guidance on tax incentives for renewable energy?
- What are the requirements for claiming the ITC and pitfalls to avoid?
- Understanding the progress expenditure rules, MACRS, and bonus depreciation rules
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Recognize federal tax issues presented when structuring renewable energy transactions
- Understand ownership structures commonly used in renewable energy transactions
- Ascertain guidance on implications of "direct pay" and recent legal and tax developments
- Understand the requirements for claiming the ITC and pitfalls to avoid
- Identify the challenges of the progress expenditure rules, MACRS, and bonus depreciation rules

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.

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