Structuring Construction and Tax Equity Bridge Financings for Wind, Solar, and Battery Storage Projects After the OBBBA

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Course Details
- smart_display Format
Live Online with Live Q&A
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Energy
- event Date
Tuesday, November 18, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Live Online
On Demand
This CLE course will provide energy and finance counsel with a briefing on certain critical legal, tax, and financing considerations in wind, solar, and battery storage projects. The panel will also review avenues to obtain financing for the project and leverage existing tax incentives.
Faculty

Mr. Alperin joined Foss & Company in November of 2017. As Managing Director, he leads all aspects of the investment, origination, and asset management process for renewable energy and sustainability funds. Prior to joining Foss & Company, Mr. Alperin worked in commercial banking and led debt financing for a broad range of middle market businesses and commercial projects.

Mr. Khanna is a partner in Husch Blackwell’s Energy & Natural Resources industry group. He is a veteran finance lawyer with significant project finance experience. Mr. Khanna represents sponsors and developers, lenders, investors, contractors, and service providers on major projects and is particularly knowledgeable about financing renewable energy projects, such as solar, battery storage, and wind. His finance background is broad-based and comprehensive, and he has led teams on senior, and mezzanine secured and unsecured loan facilities as well as single and multi-investor leveraged and non-leveraged finance and lease transactions involving manufacturing equipment, transportation assets, and other tangible and intangible assets. In addition to traditional bank lending and project finance, Mr. Khanna advises clients on the securitization of a variety of financial asset classes (including loans, leases, receivables, and payment intangibles). He is a member of the firm’s Executive Board and is a member of the APISWANA Employee Resource Group.
Description
Financings of wind, solar, and battery storage projects are complex transactions involving the assessment of evolving tax incentives and the resolution of unique legal and financing issues.
Recent legislative changes under the One Big Beautiful Bill Act (OBBBA) have significantly modified the Inflation Reduction Act's provisions, including the termination of tech-neutral credits for certain projects and the introduction of foreign entity ownership restrictions. The panel will explore the current legal, tax, and financing landscape, including strategies to utilize remaining incentives.
Counsel must ensure that bridge financing structures address change of control, collateral, sponsor credit support, and compliance with new Foreign Entity of Concern (FEOC) restrictions. Contractual pitfalls, especially those requiring top-level client approval or long lead times, must be managed with an eye to updated tax regulations and construction timelines.
Listen as our panel of authoritative practitioners provides their perspectives and analyses on the evolving tax incentives, documentation, and financing issues for wind, solar, and battery storage projects
Outline
I. Introduction
II. Overview of current tax incentives and benefits, including changes under the OBBBA, such as placed-in-service deadlines, phase-out schedules and compliance with FEOC restrictions
III. Review of bridge financing structures and documentation
IV. Change of control, collateral, sponsor credit support, and other financing considerations
V. Contract issues and regulatory considerations impacting project development and financing
VI. Practitioner takeaways
Benefits
The panel will review these and other key issues:
- How are construction and tax equity bridge financings structured under the revised Inflation Reduction Act and OBBBA?
- What are the unique issues in negotiating and structuring such financings?
- How do various contract terms and deal issues affect financing and tax incentives?
- What are the implications of the FEOC restrictions and placed-in-service deadlines on financing strategies?
- How do direct pay and transferability mechanisms function under final IRS regulations?
- What impact do the phase-out timelines and bonus credit limitations have on project viability?
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