Wolfram Pohl

Wolfram Pohl, a tax partner in the San Francisco office, focuses on the tax aspects of project finance and corporate transactions, with an emphasis on renewable energy and infrastructure projects.

• Engagements

  Recent representative transactions include advising:

  • A leading developer in the tax equity financing for a portfolio of seven wind projects in Kansas, Oklahoma, South Dakota and Texas.
    
    
  • A solar developer in the tax equity financing for a 100 MW solar project in California.
    
    
  • A utility in a build own transfer transaction to acquire a 98 MW repowered wind farm.

  • A solar developer in a module supply agreement intended to qualify under the 5% safe harbor test for beginning construction for ITC purposes.

  •  A wind developer in a turbine supply agreement intended to qualify under the 5% safe harbor test for beginning construction for PTC purposes.

  • A solar developer in the negotiation of a power purchase agreement for a solar facility, including advising on the tax implications of the battery storage provisions.

  • A solar developer in the tax equity financing of a 60 MW solar project in California.

  • A wind developer in a transformer supply agreement intended to qualify under the off-site physical work test for beginning construction for PTC purposes.

  • A solar developer in the tax equity financing of two solar projects in Massachusetts.

  • A developer in the development of an open loop biomass electricity facility, including issues relating to the scope of what qualifies as part of the biomass facility

  • A wind developer in the tax equity financing of a 200 MW wind project eligible for production tax credits.

  • A renewable power plant owner and operator in the acquisition of a 930 MW portfolio of seven wind power plants with a combined value of $2 billion.

  • A wind developer in the sale of a 182 MW wind project eligible for production tax credits.

  • A wind farm owner, in tax equity financing of a 91 MW wind project in Colorado.

  • A Spanish renewable energy company in the sale of a partial stake in a portfolio of United States wind farm assets totaling 599 MW.

  • A fuel cell developer in a partnership flip transaction for ITC eligible fuel cell servers.

  • A tax equity investor in a partnership flip transaction for an ITC-eligible solar project.

  • The concessionaire in a utility system concession for a public university, including issues relating to the tax characterization of concession fees.

  • The concessionaire in a public highway concession agreement to design, build, and operate highway express toll lanes.

  Speaking Engagements

  • Speaker, “Key Tax Issues for Battery Storage ITC” Infocast Master Class, Storage Market Opportunities, Contracting & Finance, March 2021

  • Speaker, “Begun Construction–Lessons Learned and Looking Forward” Novogradac Financing Renewable Energy Tax Credits Fall Virtual Conference, November 2020

  • Speaker, “Making the Most of Innovative Financing Strategies & Opportunities” Energy Storage North America Conference, November 2019

  • Moderator, “Dealing with the Financial Implications of Retrofitting Storage to Existing Projects and Sites” Infocast Storage Week Plus, July 2019

  • Presenter, “Clarifying that an Integral Analysis is Not Required For Storage Devices to be a Part of Solar Energy Property” California Lawyers Association Tax Section, Washington D.C. Delegation, May 2018

  • Speaker, “Securing the ITC in Solar + Storage Projects” Infocast Storage Week, February 2018

  • Speaker, "Energy Credits - Watt to Do?" American Bar Association Tax Section Fall Meeting, September 2017