Overview
Philip (Phil) Tingle represents energy companies such as utilities, independent power producers, developers and financial institutions on a wide range of energy tax-related matters. He is the global co-head of the Energy & Project Finance Practice.
Phil continues to be leader with respect to the implementation of the Inflation Reduction Act (the “IRA”) and the related incentives, tax credits and technologies. Phil provides advice regularly regarding all aspects of renewable-energy projects, including advice related to prevailing wage and apprentice, energy community adders, domestic content, project tax credit qualification, tax equity structures, financings, acquisitions and dispositions, restructurings and workouts. He has extensive experience with all technologies including wind (sections 45 and 45Y), solar (sections 48 and 48E), storage (sections 48 and 48E), nuclear (section 45U), renewable natural gas (sections 48 and 45Z), manufacturing (sections 45X and 48C), hydrogen (section 45V), carbon sequestration (section 45Q) and EV (sections 30B, 30C, 30D, 45W and 48C). Phil continues to work with client selling and buying federal and state tax credits and working with clients with the direct pay provisions pursuant to the IRA.
In addition to the IRA related work, 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.
Results
- 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
Recognitions
- Chambers USA, Projects: Renewables & Alternative Energy, 2022-2024
- Legal 500 US, Recommended, 2022-2024
Credentials
Education
University of Florida Levin College of Law, LLM, 1992
University of Florida Levin College of Law, JD, with honors, 1990
Tulane University, BSM, 1985
Admissions
Florida
