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Sean M. Moran
Sean M. Moran
Partner — Tax
Partner — Tax

Sean M. Moran

Sean M. Moran

200 West 6th Street
Suite 2500
Austin, Texas 78701

start quote symbolAs 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.end quote symbol
Sean M. Moran

Experience Highlights

  • 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


  • 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
  • Judicial clerk to The Honorable Joseph M. McLaughlin, U.S. District Court for the Eastern District of New York
  • Legal 500 U.S., Energy: Renewable/Alternative Power, 2022-2024; Finance: Project Finance, 2022-2024; Tax: U.S. Taxes: Non-Contentious, 2022-2024
  • Chambers Global, Projects: Renewables & Alternative Energy (USA), 2015–2019, 2023 and 2024
  • Chambers USA, Projects: Renewables & Alternative Energy (Nationwide), 2014–2024
  • The National Law Journal, “Energy & Environmental Trailblazer,” 2016
  • Daily Journal, “Top 100 Lawyers in California,” 2015
  • California
  • New York
  • Texas
  • “Unpacking the Freeze in Texas: Lessons Learned and a Path Forward,” V&E Energy Series CLE, May 12, 2021 (co-speaker)
  • “IRS Extends Safe Harbor for Renewable Energy Projects,” client alert, May 28, 2020 (co-author)
  • “Principal Tax Issues in Debt Restructurings,” client alert, April 30, 2020 (co-author)
  • “2018 in Retrospect: The Renewable Energy Industry in a Post-TCJA World,” Tax Notes, February 11, 2019 (co-author)
  • “Back to the Beginning: Energy Property Revisited,” Tax Notes, December 19, 2016 (co-author)
  • “The Unwind: ‘I Don’t Want It’,” Tax Notes, September 12, 2016 (co-author)
  • “Renewable Power Facilities: Placed-in-Service Issues,” Tax Notes, Vol. 151, No. 8, May 23, 2016 (co-author)
  • “Renewable Structures: Choices and Challenges,” April 2015 (co-author)
  • “Pros & Cons of Recent Renewable Energy Bill,” Law360, May 2013 (co-author)