Philip (Phil) Tingle represents energy companies such as utilities, independent power producers and financial institutions on a wide range of energy tax-related matters. He is the global head of the Firm’s Energy Advisory Practice Group.
Phil provides advice regarding all aspects of renewable-energy projects, including tax equity structures, refinancings, acquisitions and dispositions, restructurings and workouts. He has extensive experience with the production tax credit and with the application of renewable credits to new technologies. Moreover, he works with the investment tax credit for numerous kinds of solar projects. Phil has filed and received a number of private letter rulings on behalf of clients regarding the production tax credit.
Recently, Phil has worked on the many aspects of the American Recover and Reinvestment Act of 2009, including the tax implications of Section 1603 Grants, the State Energy Program Grants, and Energy Efficiency and Conservation Block Grants, the production tax credit conversion to an investment tax credit, the advanced energy credit and the sequestration credit. In addition, Phil works extensively with the Global Renewable Energy Group in the United States and internationally.
Phil also advises on the use of the New Markets Tax Credit and the Section 1603 Grant with respect to several renewable projects. He works with many buyers and sellers of electric generation and gas facilities on all aspects of mergers and acquisitions, and energy contract restructurings.
Phil regularly works on contribution in aid of construction, normalization, grants and other energy related topics. In addition, he is experienced in partnership taxation and works extensively on corporate and consolidated tax issues.
Advised an energy investor in the tax equity financing of a 235-mile 500 kV electric transmission line project
Advised a major investment bank in the tax aspects of a ground-breaking securitization involving solar energy assets across the United States
Represented an international financial services company in the legal due diligence, negotiation and preparation of transaction documents relating to their tax equity investment in a residential solar portfolio
Represented a power utility as special tax counsel in the development of a combined heat and power biomass facility in Georgia
Represented a power utility as special tax counsel for securitization of fuel cell power plants with 21 megawatts of capacity to be installed at corporate sites in California and the northeast United States