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
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 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.
Sean is recognized globally and nationwide as a Band 1 lawyer in Projects: Renewables & Alternative Energy by Chambers Global 2025 and Chambers USA 2026.
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
Education
Admissions
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
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
Deals & Cases
Vinson & Elkins advised Goldman Sachs, its West Street Climate Credit Fund (part of Goldman Sachs Asset Management’s private credit …
September 21, 2026
September 21, 2026 • 2-minute read
Deals & Cases
Vinson & Elkins Advises Lithium Americas in $175 Million Convertible Financing
Vinson & Elkins represented Lithium Americas Corp. (NYSE: LAC) (“Lithium Americas”) in connection with entry into a securities purchase agreement …
August 7, 2026
August 7, 2026 • 1-minute read
Awards & Rankings
The Legal 500 US 2026 recommended Vinson & Elkins as a leading law firm in 47 practice categories. In total, …
June 10, 2026
June 10, 2026 • 3-minute read
Awards & Rankings
Vinson & Elkins announced today that it achieved 20 Band 1 rankings in Chambers USA 2026: Nationwide: Energy Transition; Energy: …
June 4, 2026
June 4, 2026 • 3-minute read
Awards & Rankings
Chambers Global, announced today, recognizes Vinson & Elkins in 27 practice categories, including new rankings for Construction in the UAE, …
February 12, 2026
February 12, 2026 • 2-minute read
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