Troutman lawyers provide end-to-end tax equity financing counsel grounded in deep tax and project finance experience. We help clients design efficient, market-ready structures that optimize tax benefits under the IRA and related guidance. Our team addresses issues such as fair market value, bonus depreciation, pay-go features, special allocations, hedging of basis and deficit restoration risk, and change-in-tax-law protections across solar, wind, storage, and other renewable technologies.
Our team structures hybrid tax equity and transfer transactions that combine partnership models with the Inflation Reduction Act’s transferability regime. We design and negotiate partnership flips and T-flip structures to align tax benefits, cash flows, and target returns, and to accommodate tax credit transfers and preferred equity joint ventures. Drawing on current IRS guidance and market practice, we help sponsors and investors execute bankable, financeable hybrid structures that meet evolving lender and rating agency expectations.
Our lawyers advise on every stage of tax credit transfer transactions, representing sellers, buyers, and intermediaries as the transfer market develops. We structure transactions, negotiate purchase agreements, and allocate risk based on current pricing and market terms. Our team assesses credit eligibility, documentation, and recapture risk, including basis step-ups and pass-through ownership. We frequently coordinate with tax insurance providers so clients can access liquidity and broaden their investor base while maintaining compliance
Our debt finance practice supports renewable and conventional energy projects with comprehensive counsel on interim and permanent financings. We represent lenders, borrowers, issuers, and underwriters in structuring and documenting credit facilities, project loans, acquisition and leveraged financings, and hybrid project and corporate facilities. Our experience spans upstream, midstream, downstream, power, chemicals, and renewables. We also handle core project contracts and physical and financial trading and hedging arrangements, aligning financing terms with commercial risk allocation and evolving rating agency, lender, and capital markets expectations.
Our energy tax practice combines technical tax depth and industry knowledge across the energy value chain. We advise tax equity investors, lenders, sponsors, developers, and utilities on transactions involving solar, wind, storage, geothermal, waste-to-energy, biomass, hydro, natural gas, nuclear, EV infrastructure, and carbon capture. We structure acquisitions, dispositions, and financings to maximize federal, state, and local incentives. By tracking new guidance and audit trends, we help clients secure credits and deductions while managing regulatory and enforcement risk.
