Tax Considerations for Renewable Energy Transactions: Deal Structures, Tax Equity, Direct-Pay, and More
Analyzing Various Challenges in Structuring Transactions; Federal and State Credits; Abatements, Incentives, Recent Developments

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Energy
- event Date
Thursday, May 15, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE/CPE course will guide renewable energy counsel on key tax considerations and planning methods for renewable energy transactions. The panel will discuss federal tax issues, including claiming the investment tax credit (ITC), implications of direct pay and recent developments, depreciation and offsetting taxable income, ownership structuring issues, and other tax planning considerations.
Faculty

Ms. Mathieu advises public and private companies on a broad range of U.S. federal income tax matters, with a particular focus on both domestic and international transactions. Ms. Mathieu’s practice includes significant work involving the tax aspects of corporate mergers and acquisitions, spin-offs, and partnership transactions. She also advises clients with regard to the taxation of debt and equity financings, initial public offerings, and internal integration and restructuring transactions.

Description
Renewable energy financing, development, and operations hinge on practical analysis of available tax planning techniques. Renewable energy counsel structuring projects and financing must have a complete understanding of federal income tax issues impacting the profitability of renewable energy projects.
Federal legislation incentivizes commercial and residential renewable energy investment and development with the existing ITC. The technology-neutral ITC, effective Jan. 1, 2025, replaces the legacy ITC for facilities placed in service after Dec. 31, 2024. Maximizing the benefits of the ITC and other tax incentives is critical to renewable energy transactions impacting an investor's desired return and exit, along with amounts to be paid to developers. Energy counsel must have in-depth knowledge of ITC requirements, the impact on tax basis, depreciation rules, and fundamental ownership structures commonly used in renewable energy transactions.
Listen as our panel discusses federal tax issues for renewable energy transactions, including claiming the ITC, potential implications of direct pay and recent developments, depreciation and offsetting taxable income, ownership structuring issues, and other tax planning considerations.
Outline
- Federal tax issues: ITC, tax basis, depreciation
- Ownership structures commonly used in renewable energy transactions
- Ownership structuring challenges: key provisions and areas for negotiation
- Implications of direct pay and recent developments
Benefits
The panel will review these and other key issues:
- What federal tax issues are present when structuring renewable energy transactions?
- What ownership structures are commonly used in renewable energy transactions?
- What are the implications of "direct pay" and recent developments?
- What are the critical considerations for counsel in light of recent legislation and guidance on tax incentives for renewable energy?
- What are the requirements for claiming the ITC and pitfalls to avoid?
- Understanding the progress expenditure rules, MACRS, and bonus depreciation rules
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Unlimited access to premium CPE courses.:
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Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
- Annual access
- Available live and on-demand
- Best for legal, accounting, and tax professionals
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