Adam C. Kobos

Partner

Portland
San Francisco
Business Phone: 503.290.2321
Business Fax: 503.290.2405

adam.kobos@troutman.com

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Adam Kobos is a partner whose practice encompasses a wide array of tax matters for energy industry clients, including utilities, tax equity investors, and project developers and sponsors. Adam regularly represents clients who develop, acquire, or invest in renewable energy projects (including wind, solar, geothermal, waste-to-energy, biomass, hydroelectric, and other renewable energy generation facilities), energy storage facilities, and electric vehicle charging and other alternative fuel refueling facilities. He helps clients qualify for federal, state and local tax incentives and implement transaction structures that maximize the value of those incentives, including partnership flips, sale-leasebacks, inverted leases, and prepaid power purchase agreements.

Adam also represents clients in mergers and acquisitions, debt and equity offerings, transactions involving partnerships, LLCs, and other pass-through entities, and tax controversy matters.

Representative Transactions

  • Represented investor in connection with the sale-leaseback of a 15MW North Carolina solar project.
  • Represented investor in connection with a partnership flip for a 45MW California solar project.
  • Represented sponsor in connection with a partnership flip for a 25MW California solar project.
  • Represented sponsor in connection with an investment by a cash equity investor for a 43MW portfolio of solar projects.
  • Represented sponsor in connection with a partnership flip for a 50MW portfolio of DG solar projects.
  • Represented investor in connection with the sale-leaseback of a 20MW California solar project.
  • Represented investor in connection with the sale-leasebacks of a 6MW portfolio of California solar projects.
  • Represented investor in connection with the acquisition of a 95MW South Dakota wind project.
  • Represented seller in connection with the sale of 3 natural gas-fired, combined cycle facilities aggregating 165MW.
  • Represented investor in connection with the acquisition of a 20MW South Dakota wind project.
  • Represented investor in connection with the acquisition of a 50% interest in a 75MW Nebraska wind project.

Publications

  • "Recent Developments in the Taxation of Transferable State Tax Credits," Journal of Corporate Taxation, July/Aug. 2011
  • "IRS Issues Settlement Guidelines for Application of Section 118 to Location Tax Incentives," Journal of Corporate Taxation, May/June 2011
  • "Bosamia: The Tax Court Revisits Section 481 and Accounting Method Changes," Journal of Corporate Taxation, Mar./Apr. 2011
  • "Bergbauer Expands the Danielson Rule While Narrowing Section 83," Journal of Corporate Taxation, Sept./Oct. 2010
  • "Rev. Rul. 2009-39 Provides Guidance for Correcting Employment Tax Errors," Journal of Corporate Taxation, May/June 2010
  • "Schering-Plough Corp. Createli Confusion," Journal of Corporate Taxation, Jan./Feb. 2010
  • "ARRA Alters the Landscape of Renewable Energy Project Finance," Journal of Corporate Taxation, Nov./Dec. 2009
  • "Proposed Regulations Extend 'Share-by-Share Approach' to Basis Recovery in Distributions," Journal of Corporate Taxation, May/June 2009
  • "Final Regs. Simplify Continuity-of-Interest Rule for Insolvent Corporations," Journal of Corporate Taxation, Mar./Apr. 2009
  • "Renewable Energy Aspects of the American Recovery and Reinvestment Act," Biofuels International, Mar. 26, 2009 (coauthor)
  • "Rev. Rul. 2008-25 Refines (and Revises) the Law of Two-Step Acquisitions," Journal of Corporate Taxation, Sept./Oct. 2008
  • "Federal Tax Incentives for Green Buildings," Sustainable Land Development Today, July/Aug. 2008 (coauthor)
  • "Final Regulations Concerning Allocations of Boot and Basis in Reorganizations and Section 355 Distributions," Journal of Corporate Taxation, May/June 2008

Professional and Community Involvement

  • Member, American Bar Association, Tax Section
  • Member, Oregon State Bar Association, Tax Section
  • Member, Board of Trustees, Oregon Episcopal School

Rankings and Recognition

  • Portland Business Journal "Forty under Forty," 2013.

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Education

  • Stanford University, J.D., 2002
    Order of the Coif
  • Harvard University, A.M., 1998
  • Amherst College, A.B., summa cum laude, 1995
    Phi Beta Kappa

Bar Admissions

  • Oregon
  • California

Court Admissions

  • U.S. Tax Court