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 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.
Outline
- Current state of the solar finance market and trends for the near future
- Choosing the appropriate tax equity structure
- Sale-leaseback
- Inverted lease
- Partnership flip
- Evaluating the tax risks
- Current issues in deals
Benefits
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?
Faculty
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
Ms. Jacques is a senior associate in Norton Rose Fulbright's New York office. Gabrielle's practice is focused on federal income tax law, with particular emphasis on renewable energy transactions.
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Hilary Lefko
Partner
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
Ms. Lefko focuses her practice on all areas of federal income tax law, with a particular emphasis on tax controversy and renewable energy tax issues. She represents developers and investors in various energy and renewable energy projects, including transactions involving section 45 production tax credits for the production of electricity from renewable resources, including the purchase and sale of wind, open-loop biomass, landfill gas, geothermal and refined coal facilities. Ms. Lefko also advises on section 48 investment tax credits for solar projects, the Section 1603 Treasury Grant Program and other renewable energy incentives.
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