Overview
Michael Rodgers advises sponsors, lenders and investors in connection with renewable energy projects in the wind, solar, hydro fuel cell and carbon capture spaces. In particular, he has experience in structuring, planning and negotiating infrastructure and renewable energy transactions, with an emphasis on flip partnership structures, repowering transactions and the qualification of projects for federal income tax credits, including the credit for electricity produced from certain renewable resources under Section 45 of the Internal Revenue Code (PTC), the energy investment tax credit under Section 48 of the Internal Revenue Code (ITC) and the credit for carbon oxide sequestration under Section 45Q of the Internal Revenue Code (Carbon Capture Credit).
Michael also has extensive experience in cross-border tax planning and has focused on numerous tax-efficient structuring plans for a wide variety of public and private clients, including private equity funds and strategic buyers involved in both domestic and cross-border mergers, acquisitions, spinoffs, restructurings and other transactions. He has also assisted both individual clients and businesses with "inbound" issues, relating to the tax consequences and best practices associated with foreign investment and business activities in the United States, as well as "outbound" issues, involving Americans investing or doing business abroad.
Work Highlights
- REE Automotive Ltd.: advising an Israel-based electric-vehicle technology startup, on its US$3.6bn go-public acquisition by 10X Capital Venture Acquisition Corp. (NASDAQ: VCVCU), a SPAC.*
- GE Energy Financial Services: advising as tax equity investors in a 250MW Amadeus wind farm in Texas.*
- A US$200bn global services fund: advising on tax equity investments involving renewable energy projects by providing international tax structuring advice and technical tax analysis.*
- VIA Motors International, Inc.: advising this electric commercial vehicle company on its acquisition (in an all-stock merger valued at up to US$630m) by Ideanomics, Inc., a global company focused on driving the adoption of commercial electric vehicles and associated energy consumption.*
- Korea Midland Power (KOMIPO): advising as cash equity investors on:
- a 130MW ground-mounted solar photovoltaic generating facility and associated infrastructure located in Texas.
- a 160MW solar photovoltaic power plant located in Texas.* - East West Bank: advising: 1. as tax equity investor in a 7.4MW fuel cell power plant located in Connecticut. 2. as sole term lender, with respect to two operating biomass projects in California and Quebec.*
- A billion-dollar private equity fund: advising in connection with tax planning and structuring advice for various acquisitions of portfolio companies throughout Europe and South America.*
- An affiliate of Sixth Street Partners: advising on a US$402m overriding royalty interest acquisition and joint venture with Antero Resources Corporation.*
- A syndicate of commercial and institutional lenders led by Société Générale: advising on the up to US$1.25bn financing of the development of the deepwater Shenandoah field in the U.S. Gulf of Mexico and related offshore infrastructure being developed by Beacon Offshore Energy, Navitas Petroleum and Houston Energy Quantum.*
- A global high-tech conglomerate: advising in connection with tax planning, withholding tax and debt financing considerations as a means to facilitate internal corporate restructuring.*
*Includes matters handled prior to joining Linklaters*
Admissions