Tax Equity Structuring in Light of Tax Reform: Risks and Opportunities
Join a panel of key thought leaders and tax professionals assembled by The Knowledge Group as they bring the audience to a road beyond the basics of Tax Equity Structuring and as they delve into the depth-analysis of the looming opportunities and risks surrounding this significant topic. Speakers will provide a sneak peek of the recent trends and developments with regard to the 2017 tax reform under the Trump administration. They will give highlights to the remarkable impact of the recent developments to tax equity structuring. Furthermore, speakers will also provide the audience with practical strategies and practices to avoid pitfalls and costly lawsuits in a rapidly evolving legal climate.
Key topics include:
- The US Tax Reform
- The IRS’s Updated Guidance for Tax Credit Qualification
- Recent Trends and Developments in the Tax Equity Market
- Opportunities and Pitfalls
- What Lies Ahead in 2018
Durham C. McCormick Jr., Partner
James T. Tynion III, Partner
Morgan Lewis & Bockius LLP
- Business as usual for Renewables – Renewables, particularly wind, were on the cutting block during tax reform. In the end, the ITC and PTC remained unchanged, thus it is business as usual for renewables. (misses on inflation adjustment for PTC and corporate AMT).
- Summary of key tax reform items that will effect renewables – Corporate tax rate decrease to 21%, limited interest expense deductions, 100% bonus depreciation, NOLs, partnership technical terminations, BEAT and Section 199 deductions
- How with tax equity react to 20% haircut of tax credits and will the this loss be economically the burden of tax equity, or the project sponsor?
- What pros/cons does tax reform pose for renewable projects in various stages (i.e., under development, under construction, just commenced operation, after several years of operation and after the flip date).
- What to look for in 2018 with potential extender bills being introduced.
Who Should Attend:
- Federal Tax Lawyers
- Tax Accountants
- Tax Attorneys
- Tax Equity Investors
- Tax Credit Professionals
- Tax Directors
- Tax Advisers
- Tax Compliance Officers
- In-House Counsel
Durham focuses his practice on tax structuring for renewable energy transactions, with a particular emphasis on production tax credits (PTC), investment tax credits (ITC) and Section 1603 Treasury Grants.
Durham’s renewable energy experience includes project developments, joint ownership arrangements, power purchase agreements, transmission agreements, turbine supply agreements, balance of plant contracts, financings, acquisitions, divestures and operational matters. He also has significant experience representing clients with their mergers and acquisitions, finance ventures, capital raises and general governance.
Durham focuses his practice on tax structuring for renewable energy transactions, with a particular emphasis on production tax credits (PTC), …
Jim Tynion is a partner in the New York office of Morgan Lewis & Bockius, and is the head of the firm’s Energy Transactions Practice. Jim has been active in the power Project Finance sector for over 30 years, and active in wind energy, solar energy projects and financings for over 25 years. He regularly represents project sponsors, investors and tax equity investors in renewable energy development, M&A and financing transactions. Jim has an active practice in “tax equity” financings of renewable energy projects, and has been a participant in this market since it began in 2003.
Mr. Tynion is a regular speaker and panel moderator at renewable energy conferences, and is a ranked leading practitioner in this area by Chambers in the Projects - Renewables & Alternative Energy category. He was ranked as one of the top 100 lawyers in the world working in the wind energy sector in the Legal Power List 2016 by the publication, A Word About Wind. Jim is a graduate of Georgetown University’s School of Foreign Service, and the Fordham University School of Law, where he was Editor-in-Chief of the Fordham International Law Journal.
Jim Tynion is a partner in the New York office of Morgan Lewis & Bockius, and is the head of …
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Method of Presentation:
On-demand Webcast; Group-Internet Based
Experience in Tax Law
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes - Technical
1.0 CPE; 1.0 IRS-CE
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About McGuireWoods LLP
McGuireWoods is a strong, well-respected and expanding firm with a legacy reaching back more than 180 years. This legacy is a testament to our lawyers’ experience across business and industry, as well as our consistent ability to deliver an excellent legal product — efficiently and at a fair price. Some of our clients have been with us for nearly 50 years, which speaks to the level of service we provide and the mutual loyalty we engender.
About Morgan Lewis & Bockius LLP
Morgan Lewis is a full service global law firm with more than 2,200 attorneys with 30 offices in North America, Asia, Europe, and the Middle East. Morgan Lewis has more than 65 attorneys in its energy transactions practice and more than 80 lawyers in its energy regulatory practice. The firm’s project finance team is supported by experienced tax, real estate, permitting and other specialists located throughout the Firm. Morgan Lewis also provides litigation, corporate, finance, restructuring, employment and benefits, and intellectual property services in all major industries, helping clients address and anticipate challenges across vast and rapidly changing landscapes. The firm works with clients ranging from established, global Fortune 100 companies to enterprising startups.