Driving Demand: Tax Credits Fuel Growth in Renewable Energy

Infralogic
5 minute read | March.04.2024

Tax credits are unlocking capital and encouraging developers to pursue renewable energy projects, Orrick’s Alejandra Garcia Earley and John Eliason said in a recent interview with Infralogic.

The 2022 Inflation Reduction Act has led to an “explosion” in tax credit transfers that will “transform the market,” partly by making credits available to more companies, Alejandra said.
An advanced manufacturing production credit “is spurring foreign manufacturers to reopen stateside factories,” John said.
Meanwhile, the offshore wind sector is poised to play a significant role in U.S. renewable-energy production despite recent hiccups.

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Authors

Alejandra Garcia Earley Partner, Renewable Energy, Power

Chicago

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D:+1 312 924 9825
E: [email protected]

Practice:

Renewable Energy
Power
Energy & Infrastructure

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Alejandra Garcia Earley Partner

Chicago

Alejandra advises sponsors, lenders and agents on all aspects of a project, from drafting, negotiation and review of traditional project documents, including EPCs, O&Ms and MSAs through procuring construction financing and term loans for the operation and maintenance of the asset. Her tax equity practice includes drafting and negotiating the traditional tax equity partnerships (for PFlip and TFlip structures) documentation, tax credit transfer agreements and advising construction and back leverage lenders in connection with tax equity portfolios.

Alejandra’s experience spans a range of power generating technologies and projects, from solar, wind and hydro to biofuel, carbon capture, oil and gas and LNG projects. She has also led financings for major international infrastructure projects such as airports, water treatment, power generation and toll roads.

A native Spanish speaker, Alejandra has worked extensively across Latin America, including Mexico, Chile, Uruguay, the Dominican Republic and Colombia.

John Eliason Partner, Tax, Renewable Energy

Washington, D.C.

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D:+1 202 339 8546
E: [email protected]

Practice:

Energy & Infrastructure Sector
Finance Sector
Tax
Renewable Energy
Energy

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John Eliason Partner

Washington, D.C.

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.