John Eliason

Partner

Washington, D.C.

In his more than 20 years of advising tax equity investors and developers, John has played a pivotal role in the advancement of the renewables and alternative energy market. He continues to provide leadership in this ever-changing sector by guiding clients on the implications of the IRA, helping them navigate new rules in order to maximize federal and state tax benefits.

John advises major financial institutions (tax equity investors and infrastructure funds), lenders, developers, and sponsors, particularly those in the wind, solar, storage, biomass and energy tech space. He helps clients structure financings for their projects to take advantage of federal and state tax incentives, like the Federal production tax credit (PTC), energy investment tax credit (ITC) and accelerated depreciation (MACRS and “bonus”) using partnership flips, sale-leasebacks, public/private partnerships, and other structuring options. He has been particularly focused on providing clients with the latest guidance and opportunities relating to the Inflation Reduction Act, including with respect to Section 6418 tax credit transfers and Section 6417 direct pay opportunities.

Recognized by Chambers USA and Chambers Global in Band 2 for Projects: Renewables & Alternative Energy, clients describe John as “extremely knowledgeable, flexible and can put technical jargon into plain terms.” Client sources also state “he knows the tax equity markets very well and is very commercial.”

Prior to law school, John founded an information management company based in Austin, Texas. He is also a veteran of the Texas Army National Guard.

Engagements
Project Finance
- Represented leading financial institution in tax equity investment in a 210 MW, $465 million wind farm in Illinois, structured as a “partnership flip.”
- Developed renewables syndication platform for leading financial institution, with environmental finance goal of $50 billion invested by 2030.
- Represented leading financial institution in $60 million tax equity financing of solar DG portfolio in Northeastern United States, structured as a “partnership flip.”
- Represented major financial institution in structuring and closing syndication of solar portfolio – the first renewable energy syndication by institution.
- Represented global energy provider in tax equity and debt financing of 400 MW portfolio of four wind repowering projects, structured as a “partnership flip.”
- Represented leading financial institution in $125 million tax equity investment in utility scale solar facility in Texas, structured as a “partnership flip.”
- Represented regional financial institution in creation and successful implementation of solar DG sale-leaseback program.
- Represented foreign infrastructure fund with acquiring “cash equity” components of solar portfolio.
- Represented global financial institution in a $290 million tax equity acquisition of a 128 MW wind farm in California, structured as a “prepay PPA.”
- Represented solar developer in tax equity financing of portfolio of utility scale solar projects in Massachusetts – the first solar transaction for developer.
- Represented solar developer in first transaction of tax equity and debt financing for portfolio of solar projects, structured as a “lease pass-through.”
- Represented developer in tax equity and debt financings of 70 MW biomass plant in Southeastern United States, structured as a “partnership flip.”
- Represented leading financial institution in tax equity investment in 300 MW solar project in California, structured as a “partnership flip.”
- Represented leading sponsor in tax equity financing of 100 MW solar plus storage project in California, structured as a time-based “partnership flip.”
- Represented US private equity fund with acquiring $150 million JV interest in multiple residential solar portfolios.
- Represented US solar developer in creation and implementation of “start of construction” strategy supporting over 2 GW of project pipeline.