Andrew P. Nelson

Andrew advises businesses and individuals on a wide range of tax matters, including tax and structuring analysis for mergers and acquisitions, financings, joint ventures, and private equity transactions. He also represents partnerships, limited liability companies, corporations, joint ventures, and tax-exempt entities in various transactional and business needs, including entity formation and drafting operating agreements.

Andrew has experience with transactions involving renewable energy projects and advising businesses on the impact of the Inflation Reduction Act of 2022.

Andrew also has experience representing individuals and businesses in tax disputes with the Internal Revenue Service and assisting in tax litigation before the U.S. Tax Court.

• Assisted in representing a renewable developer and owner-operator of utility-scale solar energy projects in the acquisition of a portfolio of development-stage solar projects.
• Assisted in representing the developer of solar energy projects in analyzing the eligibility for tax credits under the Inflation Reduction Act of 2022 and negotiating the sale of eligible tax credits to a third party.
• Assisted in representing a hydropower developer in analyzing the eligibility for energy credits under Code Section 48 and the Inflation Reduction Act of 2022.
• Assisted in representing the developer of a carbon capture, transport, and sequestration project in drafting and negotiating a joint venture agreement.
• Assisted in advising a consortium of established investors in the solar energy industry, including an affiliate of Greenbacker Capital Management, LLC, in the acquisition of Sunlight Financial Holdings.
• Assisted in representing Greenbacker Capital Management, LLC, in its strategic investment in Swell Energy, a California-based residential energy storage developer and aggregator.
• Assisted in representing Kelvin, a national leader in intelligent HVAC solutions, to form an exclusive partnership with ClearGen LLC, a provider of capital for innovative energy solutions.
• Assisted in representing Trinity Gas Storage, LLC, in its funding for its natural gas storage facility in East Texas.
• Assisted in representing Pinnacle Midstream in its sale to Phillips 66.
• Assisted in representing WildFire Energy I LLC, an independent energy platform company, in the acquisition of approximately 237,000 net acres and interests in 465 wells in the East Texas Eagle Ford from Apache Corporation and subsidiaries.
• Assisted in representing an oilfield services company in an equity-for-equity combination transaction.
• Assisted in representing an oil and gas company in an underwritten public offering of 40 million shares of common stock.
• Assisted in representing a midstream oil and gas company in an initial capital commitment of $400 million.
• Assisted in representing an oil and gas company in a crude oil prepayment agreement.
• Assisted in representing many business and individual taxpayers in federal tax disputes with the Internal Revenue Service, including misclassification of workers and providing Section 530 relief.