Sean M. Moran

Partner

Tax

“As technology and power generation have continued to evolve and grow exponentially, we have evolved as well by innovating financial and legal structuring and finding solutions that are embraced by all stakeholders in the zero and carbon neutral power space.”

Sean Moran

Overview

Sean focuses on asset finance, with an emphasis on financing, acquiring, and disposing of renewable energy, zero carbon, and infrastructure assets. Instrumental in creating the structure that has become the standard for renewable energy deals in the United States, Sean has handled many of the country’s largest and most complex renewable energy financing transactions, including numerous first-of-its-kind deals.

In the course of his practice, Sean represents Fortune 50 companies, tax equity investors, private equity funds, sponsors, developers, lenders, and borrowers. His clients include some of the largest investors in the renewable energy market, collectively investing billions of dollars in renewable energy generation. His projects include wind; solar; battery storage; hydrogen; geothermal; biomass, renewable natural gas (RNG), sustainable aviation fuel (SAF), and other renewable fuels; carbon capture and sequestration; electric vehicles; and manufacturing and mining. His experience includes tax equity, tax credit finance and sales, M&A and joint ventures, reorganizations and bankruptcy, project finance, and structured finance. Sean has worked with dozens of clients and stakeholders to develop and execute on structures utilizing monetization opportunities available through the Inflation Reduction Act.

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Experience

  • Global Infrastructure Partners in the acquisition of a 50% interest in the multi-billion dollar South Fork and Revolution Offshore Wind Projects from Eversource Energy, including the negotiation of the joint venture arrangements with Orsted for the construction and operation of the projects and all financing arrangements (IJInvestor Joint Venture of the Year, 2024)

  • 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

  • 8 Rivers Capital in its joint venture with ADM to develop the 280 MW Broadwing Clean Energy Complex in Illinois, one of the world’s first zero emissions Allam-Fetvedt cycle power plants, including CO2 storage capabilities

  • 8 Rivers Capital in its joint venture with The Southern Ute Indian Tribe Growth Fund to develop the 280 MW Coyote Clean Power Project in Colorado, one of the world’s first zero-emissions NET Power natural gas-fired power plants, including CO2 capture and storage capabilities

  • NALA Renewables and Buckeye Partners in connection with the acquisition of and joint venture structuring for, the Swift Current Energy portfolio, a US portfolio of development wind and solar assets in excess of 10GW, including the construction and term financing and tax equity investments in the portfolio assets

  • Numerous tax equity investors in their initial investments in utility scale wind, solar, and storage projects including—with respect to solar and storage—commercial, industrial, and residential assets, utilizing partnership flip transactions, sale leaseback, and inverted lease structures

  • MN8 Energy in connection with the acquisition from Recurrent Energy and the development, debt and term 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

  • Goldman Sachs Renewable Power in the acquisition, joint development, and tax equity financing of a several hundred megawatts of shovel-ready C&L solar and solar-plus-storage projects across the United States

  • Numerous tax equity investors in tax equity financing of various wind repowering projects throughout the United States

  • Cypress Creek in a mezzanine debt facility, a preferred equity issuance, and recapitalization intended to optimize its capital structure as part of its long-term growth strategy

  • Tax equity investors and sponsors in the financing of numerous solar and wind projects selling power to Community Choice Aggregators

  • Multiple tax equity investors in the sale and leveraged lease-back of wind, solar and geothermal projects

  • A sponsor in the cash equity financing of several portfolios of residential and commercial solar projects with different financing parties

  • A leading solar developer in connection with a sale of operating assets and subsequent sale of the company

Credentials

Education

  • Fordham University School of Law, J.D., 1988 (Fordham Law Review, Member)
  • New York University School of Law, LL.M., Tax, 1994
  • Fordham University, B.S., 1981

Admissions

  • California
  • New York
  • Texas

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Recognitions

  • Legal 500 U.S., Energy: Renewable/Alternative Power, 2022–2024; Finance: Project Finance, 2022–2024; Tax: U.S. Taxes: Non-Contentious, 2022–2026
  • Chambers Global, Projects: Renewables & Alternative Energy (USA), 2015–2019, 2023–2026
  • Chambers USA, Projects: Renewables & Alternative Energy (Nationwide), 2014–2026
  • The Best Lawyers in America© (BL Rankings, LLC), Energy Law (Austin), 2025–2027
  • Selected to the 500 Global Tax Lawyers, Lawdragon, 2025 and 2026
  • The National Law Journal, “Energy & Environmental Trailblazer,” 2016
  • Daily Journal, “Top 100 Lawyers in California,” 2015
Insights

Client Alerts

Storing Up Certainty: IRS Expands the 45Q Safe Harbor

On August 14, 2026, the Internal Revenue Service (“IRS”) issued its Notice 2026-50 (the “2026 45Q SH Notice”), which expands …

August 17, 2026

August 17, 2026 • 3-minute read

Client Alerts

5% Safe Harbor Resurrected for Wind and Solar (At Least for Now)

On Saturday, June 6, 2026, the U.S. District Court for the District of Columbia (the “District Court”) vacated Internal Revenue …

June 8, 2026

June 8, 2026 • 2-minute read

Articles

Applying the Single Energy Project Framework to Prevailing Wage and Apprenticeship Requirements Under the Technology Neutral ITC

The Inflation Reduction Act of 2022 introduced the Clean Electricity Investment Tax Credit under section 48E of the Code[1] (the …

May 15, 2026

May 15, 2026 • 5-minute read

Articles

Energy Tax Credits in 2026: A Tale of Two Markets

The One Big Beautiful Bill Act’s sweeping reforms have reshaped tax planning across much of the U.S. economy, but no …

March 17, 2026

March 17, 2026 • 4-minute read

Client Alerts

Material Assistance Guidance Released, Leaving Taxpayers Wanting More

On February 12, 2026, the Treasury Department (the “Treasury”) and the Internal Revenue Service (the “Service”) released IRS Notice 2026-15 …

February 13, 2026

February 13, 2026 • 5-minute read

News & Achievements