Wolfram Pohl

Partner

San Francisco

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.

Wolf represents many of the country’s most prominent developers and financing parties in structuring transactions to take advantage of tax credits, Treasury cash grants, depreciation benefits, and other available tax benefits. He has represented developers and tax equity investors in financings of both wind and solar projects, as well as on tax planning for energy storage, carbon capture, and carbon sequestration projects. 

  • Wolf also advises sponsors on public-private partnership arrangements for large infrastructure projects, as well as on tax-exempt bond financings for multifamily housing projects.  He has advised on a variety of other tax issues, including equity and debt financings, mergers and acquisitions, public offerings, and real estate transactions.

  • 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

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