Andrew P. Nelson

Andrew Nelson advises businesses and individuals on a wide range of tax matters, including tax and structuring analysis for mergers and acquisitions, financings, joint ventures and private equity transactions. Andrew also represents partnerships, limited liability companies, corporations, joint ventures and tax-exempt entities in various transactional and business needs, including entity formation and drafting operating agreements.

Most recently, Andrew has had a particular focus on transactions involving renewable energy projects and advising businesses on the impact of the Inflation Reduction Act of 2022.

Andrew also has experience representing individuals and businesses in tax disputes with the Internal Revenue Service and assisting in tax litigation before the U.S. Tax Court.

Andrew’s experience includes assisting in the representation of:

• Renewable developer and owner-operation of utility scale solar energy projects in the acquisition of a portfolio of development-‎stage solar projects
• Developer of solar energy projects in analysis of eligibility for tax credits under the Inflation Reduction Act of 2022 and negotiation of the sale of eligible tax credit to a third party
• Hydropower developer in analysis of eligibility for energy credits under Code Section 48 and the Inflation Reduction Act of 2022
• Developer of carbon capture, transport and sequestration project in drafting and negotiating joint venture agreement
• A consortium of established investors in the solar energy industry, including an affiliate of Greenbacker Capital Management, LLC, in the acquisition of Sunlight Financial Holdings
• Greenbacker Capital Management, LLC, in its strategic investment in Swell Energy, a California-based residential energy storage developer and aggregator
• Kelvin, a national leader in intelligent HVAC solutions, to form an exclusive partnership with ClearGen LLC, a provider of capital for innovative energy solutions
• Trinity Gas Storage, LLC, in its funding for its natural gas storage facility in East Texas
• Pinnacle Midstream in its sale to Phillips 66
• WildFire Energy I LLC, an independent energy platform company, in the acquisition of approximately 237,000 net acres and interests in 465 wells in the East Texas Eagle Ford from Apache Corporation and subsidiaries
• Oilfield services company in an equity-for-equity combination transaction
• Oil and gas company in an underwritten public offering of 40,000,000 shares of common stock
• Midstream oil and gas company in an initial capital commitment of $400 million
• Oil and gas company in a crude oil prepayment agreement
• Many taxpayers (businesses and individuals) in federal tax disputes with internal revenue service, including misclassification of workers and providing Section 530 relief