BarbriSFCourseDetails
  • videocam Live Online with Live Q&A
  • calendar_month October 30, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Energy
  • schedule 90 minutes

Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases, Partnership Flips, Tax-Credit Transfers

Changes After OBBBA, Choosing the Right Structure, Weighing Advantages and Drawbacks of Various Structures

$297.00

This course is $0 with these passes:

CLE
ALL
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Description

There are now four primary paths for monetizing solar tax incentives: the three traditional tax equity structures and the post-IRA transferability option under IRC §6418. The OBBBA has significantly changed the timeline, accelerating the phase out of tech-neutral credits (45Y/48E) after 2027 and ending the residential solar credit (25D) after 2025, making construction-start strategy essential.

IRS final rules on elective pay (6417) and transferability (6418) have standardized market practices for registration, documentation, and "paid-in-cash" requirements. Sponsors are increasingly pairing credit transfers with bridge financing, back-leverage debt, and tax insurance to optimize returns. Our panel will explore how to position projects to meet the prevailing wage and apprenticeship and domestic content requirements while maximizing value.

Listen as our panel covers the updated deal landscape, compares the structures in light of current policy changes, and shares strategies for mitigating risks and seizing opportunities before the next round of phaseouts.

Presented By

Gabrielle Jacques
Senior Counsel
Norton Rose Fulbright, LLP

Ms. Jacques is a senior associate in Norton Rose Fulbright's New York office. Gabrielle's practice is focused on federal income tax law, with particular emphasis on renewable energy transactions.

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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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Credit Information

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


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, October 30, 2025

  • schedule

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

I. Introduction

II. Current state of the solar finance market and trends for the near future

III. Choosing the appropriate tax equity structure

A. Sale-leaseback

B. Inverted lease

C. Partnership flip

D. Tax-credit transfer under Section 6418

IV. Regulatory framework and deadlines

V. Key negotiation points

VI. Practitioner takeaways

The panel will review these and other noteworthy issues:

  • When to choose one structure over another or hybridize
  • What are the main issues on which the parties spend the most time in negotiations?
  • Strategies to meet construction-start deadlines for 45Y/48E eligibility before OBBBA phaseouts
  • Key negotiation points: basis step-ups, change-in-law allocation, DROs, flip yields, tax insurance, recapture coverage, unwinds
  • How credit transfers are priced, documented, and paired with bridge/back-leverage facilities
  • Practical implications of PWA/apprenticeship and domestic content rules on deal structure