
Ben Livni

Two California Plaza
350 South Grand Avenue
Suite 2100
Los Angeles, California 90071

Ben’s practice focuses on tax matters related to asset finance, with an emphasis on renewable energy, zero carbon, and infrastructure assets. Ben has experience utilizing a variety of structures in the finance, disposition, acquisition, and development of clean energy projects including solar, wind, energy storage, carbon sequestration, and hydrogen. Ben also advises clients more broadly in connection with tax issues related to capital markets and derivative products, M&A and private equity, and reorganization and bankruptcy.
In the course of his practice, Ben regularly represents Fortune 50 companies, investors, utilities, sponsors, and developers in the clean energy space.
The following is a list of representative matters in which Ben has assisted.
Experience Highlights
LSB Industries in its agreement with Lapis Energy for the development of a project to capture and permanently sequester CO2 from ammonia production at LSB’s El Dorado, Arkansas facility
Tax equity investor in their investment in two solar projects with 450 MW combined capacity in California
Major financial institution in an approximately $142 million tax equity investment in the re-powering of a 162.2 MW wind project located in Caddo and Kiowa Counties, Oklahoma; the re-powered project will be operated by a market leading wind energy developer, and its affiliates, and will sell power and environmental attributes pursuant to a long-term power purchase agreement with an off-taker located in a different regional power market
Tax equity investor in the financing of 239 MW and 200.2 MW wind projects in Texas and a 148.4 MW wind facility in Oklahoma
Financial sponsor in the sale leaseback financing of a portfolio of commercial and industrial (C&I) solar photovoltaic projects in Minnesota
UK-based investor in a joint venture that is exploring numerous CCS/CCUS projects on the Gulf Coast
Tax equity investor in the financing of 8 solar facilities in New York with aggregated capacity of 215.8 MWdc
MN8 Energy (Goldman Sachs Renewable Power) in the acquisition and tax equity financing of the 150 MW solar-plus-storage High Desert Solar Project in San Bernardino County, California
Terra-Gen in the approximately $270 million construction financing and $136 million tax equity financing for the 64.5 MW Tehachapi Plains, 60.3 MW Oasis Power, and 14.4 MW Oasis Alta wind generation facilities in Kern County, California, and the 61.2 MW Coachella and 46.8 MW Painted Hills wind generation facilities in Riverside County, California
Blackstone Credit and ClearGen, a Blackstone Credit portfolio company, in the formation of a strategic partnership between ClearGen and GreenStruxure, a Schneider Electric and Huck Capital joint venture, to develop, own and operate up to $500 million of renewable energy microgrid systems for C&I customers
Private equity fund in a $150 million debut joint venture with a solar developer to acquire and develop community solar and other eligible renewable projects
Clearway Energy in the debt and tax equity financing of the 192 MW Rosamond Central solar project in Kern County, California
Tax equity investor in the sale of interests in New Market Tax Credits funds
Goldman Sachs Renewable Power in the acquisition from Recurrent Energy and the development, debt, and tax equity financing of a 300MW solar photovoltaic (PV) plus 140.25MW/561MWh storage project in California; the project will sell power pursuant to 5 separate power purchase agreements, 4 of which include energy storage
A major financial institution as tax equity investor in the financing of a 520MW combined photovoltaic (PV) solar and battery storage facility in ERCOT, a portion of the output of which is to be sold under a hedge with the balance of the energy and the storage component being utilized on a merchant basis
Credentials
- Loyola Law School, J.D. cum laude, 2018 (Los Angeles Law Review, Production Editor; Order of the Coif; Winner, Student Writing Competition, Tax Notes)
- University of California, Santa Barbara, B.A. Economics and Accounting, 2014
- Judicial extern to The Honorable Victoria Kaufman, U.S. Bankruptcy Court for the Central District of California
- Extern, U.S. Securities and Exchange Commission
- Member: American Bar Association Tax Section
- California
- Hebrew (fluent)
- InsightJune 2, 2023
V&E Renewable Energy Update
- InsightJune 2, 2023
V&E Renewable Energy Update
- InsightMay 12, 2023
V&E Renewable Energy Update
- Deals & CasesMay 2, 2023
- Treasury Quietly Changes Energy Community Guidance, Redefining Beginning of Construction Timing RuleInsightApril 10, 2023
V&E Renewable Energy Update
- InsightApril 3, 2023
V&E Renewable Energy Update
- InsightFebruary 15, 2023
- InsightFebruary 14, 2023
V&E Renewable Energy Update
- InsightNovember 30, 2022
V&E Inflation Reduction Act Update
- Deals & CasesNovember 21, 2022
- Deals & CasesSeptember 29, 2022
- Deals & CasesApril 28, 2022
- Deals & CasesMarch 7, 2022
- InsightDecember 20, 2021
V&E Tax Update
- InsightDecember 13, 2021
V&E Tax Update
- InsightNovember 19, 2021
V&E Tax Update
- InsightNovember 2, 2021
V&E Tax Update
- InsightSeptember 7, 2021
Published in Tax Notes Federal, Tax Notes State, Tax Notes International, August 9, 2021
- InsightJune 30, 2021
V&E Renewable Energy Update
- Deals & CasesJune 29, 2021
- Deals & CasesApril 16, 2021
- InsightApril 5, 2021
- InsightApril 2, 2021
V&E American Jobs Plan Update
- Deals & CasesMarch 22, 2021
- “Guide to Energy Tax Credits: The Basics to Fuel, Power, and Carbon Capture Credits,” D.C. Bar Association, May 24, 2022 (co-speaker)
- “Getting Charged Up: A Primer on Energy Tax Incentives,” ABA Midyear Tax Meeting, February 1, 2022 (panelist)
- “COVID Relief Bill Contains Energy Tax Extenders,” client alert, December 22, 2020 (co-author)
- “IRS Extends Safe Harbor for Renewable Energy Projects,” client alert, May 28, 2020 (co-author)
- “The Storm of Cloud Computing Taxation,” State Tax Notes, July 2017 (author)
News & Insights
V&E Renewable Energy Update
V&E Renewable Energy Update
V&E Renewable Energy Update