Here’s a presentation that Joseph Sebik, CPA of Siemens Financial Services and I gave to the Energy Subcommittee of the Equipment Leasing and Finance Association on January 22: Tax Equity Energy Subcommittee 1-22-19 of ELFA.
Despite being to a leasing trade association, the focus of the presentation is the partnership flip structure. The presentation includes appendices on the phase down of tax credits for solar and the phase out of tax credits for wind; the “start of construction” rules; and hypothetical liquidation at book value (HLBV).