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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

  • work Practice Area

    Energy

Date & Time
  • event Date

    Tuesday, December 13, 2022

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$347.00
CLE
ALL

This CLE webinar will provide an in-depth analysis of the new technology-neutral tax credits for the production tax credit (PTC) and investment tax credit (ITC) under the recently enacted Inflation Reduction Act of 2022 (the Act). The panel will discuss key provisions of the Inflation Reduction Act, rules and requirements of the technology-neutral tax credit, and the impact to PTC/ITC for renewable energy projects, as well as provide a critical analysis of these rules and next steps for sponsors, developers, and investors.

Faculty

Jorge Medina
Miscellaneous

Mr. Medina is a partner in the Project Development & Finance practice and Head of Renewables (Americas). He focuses on federal tax policy and controversy issues involving renewable energy and energy transition assets and he has extensive experience structuring tax-driven transactions. Mr. Medina manages the execution of tax equity and debt transactions and represents both sponsors and tax equity investors in the energy sector in connection with energy storage, wind, solar, hydrogen, renewable natural gas, carbon capture, geothermal, biofuels and electric vehicle infrastructure projects. He is deeply familiar with all forms of tax equity structures, having closed dozens of partnership flip, lease pass-through and sale-leaseback transactions. Prior to joining the firm, Mr. Medina was co-leader of energy renewables and infrastructure at his prior law firm. He also previously served as associate general counsel-tax at automotive and energy company Tesla Inc., where he was primarily responsible for all tax issues across Tesla related to the energy and storage business and served as vice president and deputy general counsel at SolarCity, which Tesla purchased in 2016.

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Hilary Lefko
Partner
Norton Rose Fulbright, LLP

Ms. Lefko focuses her practice on all areas of federal income tax law, with a particular emphasis on tax controversy and renewable energy tax issues. She represents developers and investors in various energy and renewable energy projects, including transactions involving section 45 production tax credits for the production of electricity from renewable resources, including the purchase and sale of wind, open-loop biomass, landfill gas, geothermal and refined coal facilities. Ms. Lefko also advises on section 48 investment tax credits for solar projects, the Section 1603 Treasury Grant Program and other renewable energy incentives.

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Description

The recently enacted Inflation Reduction Act extends or renews certain tax credits and other tax incentives while also providing a new technology-neutral tax credit regime for ITCs and PTCs. Energy counsel must grasp a complete understanding of key provisions of the new legislation and rules for claiming tax credits.

Both the ITC and PTC for renewable energy are critical components of successful project financing, significantly impacting ownership structures and available tax planning techniques. The PTC provides a credit for each kilowatt-hour of energy production for qualified renewable energy facilities. The ITC allows taxpayers to claim a credit for the cost of investment in qualified energy property.

The Act provides notable changes for ITC/PTC, such as the availability of such credits over the next few years, their applicability to battery storage, and new opportunities for hydrogen and nuclear projects, as well as for domestic manufacturing of components for wind and solar facilities.

A new technology-neutral tax credit applies to projects placed in service in 2025 or later and allows taxpayers to choose the PTC or ITC for all clean power technologies if all requirements are fulfilled.

Listen as our authoritative panel of energy counsel and tax professionals examines the benefits of the tax credits and discusses the recent legislation, critical requirements in claiming ITC and PTC, and the rules and requirements of the technology-neutral tax credit, as well as provides a critical analysis of next steps for sponsors, developers, and investors.

Outline

  1. Overview of energy tax credit provisions under the Inflation Reduction Act
  2. Requirements for claiming PTC/ITC and impact of the new technology-neutral tax credit regime
  3. Avoiding mishaps that jeopardize PTC/ITC in light of the new technology-neutral tax credit regime
  4. Tax equity structuring considerations for renewable energy facilities and development

Benefits

The panel will review these and other key issues:

  • Key tax credit provisions of the Inflation Reduction Act of 2022 for renewable energy
  • Requirements for claiming the ITC and PTC and the impact of the new technology-neutral tax credit regime
  • Key issues under the new rules and techniques to avoid mishaps
  • Financing structures for renewable energy projects in light of the the Act