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Renewables Tax & Tax Equity

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Chambers USA: Projects: Renewables & Alternative Energy, 2021–2025

For more than a century, Vinson & Elkins has helped clients energize the world. As the market has shifted toward renewable and sustainable sources of power, we have adapted alongside it, creating tax-efficient structures tailored to the objectives of each project’s stakeholders.

The Legal 500 US: Energy – Renewable/Alternative Power, 2018–2025

For clean energy projects, a significant share of economic value may derive from federal tax benefits designed to drive development, innovation, and investment. V&E’s tax equity and project finance team not only has deep experience navigating these incentives, which have greatly evolved with the passage of the Inflation Reduction Act and One Big Beautiful Bill Act, but also understands the ever changing dynamics of the market itself.

Our team is widely recognized for its pioneering role in the sector. We helped shape the first generation of tax equity financings across multiple asset classes, including the earliest wind production tax credit transactions in the early 2000s, where the lead role in developing the now-standard partnership flip structure. Ever since, we have been trusted advisors at the forefront of each successive wave of renewable asset finance, including solar, energy storage, wind power, geothermal, hydrogen, carbon capture and sequestration, clean fuels, electric vehicles, fuel cells, and microgrids.

Our broad client base sets us apart – we have represented every key participant in clean energy transactions, including tax equity investors, tax credit buyers and sellers, lenders, private equity funds, brokers, insurance providers, buyers, seller, and clean energy sponsors and developers. V&E’s client base comprises some of the largest and most influential companies leading the charge in the clean energy market.

Experience Highlights

  • Affiliates of Global Infrastructure Partners in the acquisition of a 50 percent interest in the multi-billion dollar South Fork and Revolution Offshore Wind Projects off the East coast of the United States 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)

  • Swift Current Energy in the ~$700 million debt financing, ~$250 million tax equity financing, and ~$270 million ITC transfers for the 800 MWdc Double Black Diamond Solar project in Illinois, which is expected to be the second largest single phase solar project in the US and the largest solar project in MISO

  • Vistra in the separate sales of $240 million of 45U nuclear power production credits

  • Palmetto Solar in a first of its kind tax equity transaction to fund landlord focused residential solar business with a global energy technology company, funding approximately $100 million in assets

  • Wells Fargo in their tax equity investment to construct the 145 MW Aragonne Mesa Wind Project and to repower the 90 MW Aragonne Wind Project, both in Guadalupe County, New Mexico

  • MN8 Energy in the (i) acquisition from Recurrent Energy (ii) project development, (iii) construction and term debt financing, and (iv) tax equity financing of a 300MW solar photovoltaic (PV) plus 140.25MW/561MWh storage project in California; which will sell power pursuant to 5 separate power purchase agreements, 4 of which include energy storage

  • Renewable project sponsor/developer in the $1.05 billion sale of tax credits to a global retailer under a first-of-its-kind framework agreement allowing tax credits to be sold from multiple tax equity partnerships

  • Developmer in the development of a power-to-liquids eFuels facility in Texas that will convert waste carbon dioxide and green hydrogen into SAF and other low carbon fuels, and in its $75 million project equity investment commitment from Breakthrough Energy Catalyst, along with advice with respect to project structuring and tax credit monetization under Section 45V and advanced biofuels tax credits under Section 45Z

  • Developer in the construction financing of the Evelyn Energy Storage Project, an approximately 220 MW / 440 MWh stand-alone battery energy storage project located in Galveston County, Texas following by representation in connection with a tax credit transfer agreement and placing tax credit insurance

  • Vitol Inc. in a landmark tax credit transfer agreement with Avangrid, Inc. to purchase an estimated $100 million of wind PTCs

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