Jorge Medina is a partner in the Project Development & Finance practice and Head of Renewables (Americas).

He focuses on federal tax policy and controversy issues involving renewable energy and energy transition assets and he has extensive experience structuring tax-driven transactions. Jorge manages the execution of tax equity and debt transactions and represents both sponsors and tax equity investors in the energy sector in connection with energy storage, wind, solar, hydrogen, renewable natural gas, carbon capture, geothermal, biofuels and electric vehicle infrastructure projects. He is deeply familiar with all forms of tax equity structures, having closed dozens of partnership flip, lease pass-through and sale-leaseback transactions.

Prior to joining the firm, he was co-leader of energy renewables and infrastructure at his prior law firm. He also previously served as associate general counsel-tax at automotive and energy company Tesla Inc., where he was primarily responsible for all tax issues across Tesla related to the energy and storage business and served as vice president and deputy general counsel at SolarCity, which Tesla purchased in 2016.

• Represented Dutch pension manager APG Asset Management NV in its purchase from Quinbrook Infrastructure Partners of a major stake in what is expected to be the largest solar project in America. APG acquired a 49% stake in the $1.2 billion Gemini project.*
• Advised Complete Solar Holding Corporation, a leading U.S. solar technology, services and financing company, in its $888 million merger with The Solaria Corporation, forming Complete Solaria, Inc.*
• Advised EV fleet charging specialist TeraWatt Infrastructure in a transaction that will provide approximately $1 billion of institutional capital to support the buildout of its fleet-focused charging centers and operations.*
• Represented S&B USA (previously Shikun and Binui America) in its acquisition and financing of the Brazoria West Solar Project with 260 megawatts of planned solar energy productivity from Savion, part of Macquarie’s Green Investment Group. Pillsbury advised on the acquisition as well as the debt financing and tax equity financing.*
• Advised CMS Energy in the acquisition, debt and tax equity of the Aviator transaction—largest wind project transaction in 2020 and short listed for multiple Deal of the Year awards.*
• Represented North American energy infrastructure company TC Energy, with operations in natural gas, oil and power industries, in a strategic deal with Nikola Corporation, a global leader in zero-emissions transportation and energy infrastructure solutions.*
• Represented Archaea Energy LLC, an emerging leader in the development and advancement of renewable natural gas (RNG), in a business combination agreement with Aria Energy LLC led by Rice Acquisition Corporation (RAC), a special purpose acquisition company focused on the energy transition sector. Following closing, the combined company will be listed on the NYSE under the ticker symbol “LFG”.*
• Advised NextEra Energy Partners, LP in its $733 million acquire of a 391-megawatt portfolio of four operating wind assets located in California and New Hampshire.*
• Represented Chanel in the development, tax equity financing for its first investment in a renewable energy transaction, funding approximately $80 million in Sunrun solar and solar plus battery storage projects on low-income, multifamily housing.*
• Represented Shikun & Binui (S&B) USA Energy in its purchase from Capital Dynamics of 108 MW in California of a solar portfolio consisting of two projects Beacon II (59.6 MW DC) and Beacon V (48.2 MW DC).*
• Represented Tesla in a first-of-its-kind tax credit monetization transaction structure for electric vehicle tax credits.*
• Handled nine IRS audits of SolarCity/Tesla’s solar funds, involving more than $500 million at issue, with no adjustments.*
• Represented SolarCity in the largest solar distributed generation tax equity transaction in history, funding over $1 billion in solar and battery storage projects.*
• Represented tax equity funds in the placement of over 30 tax insurance policies that cover hundreds of millions in indemnity exposure.*
• Counsel on the development and financing of the world’s first utility-scale solar plus battery storage generation facility in Hawaii.*
• Served as tax counsel for the first four solar securitization transactions ever completed.*

*Denotes prior firm experience

Speaking Engagements

• “New Technology-Neutral Tax Credits for ITC and PTC Regimes: Application to Facilities, Rules and Requirements, Tax Equity,” Strafford Webinar, December 13, 2022.
• “Using Partnership Flips to Finance Renewable Energy Projects: Evaluating Tax Risks, Navigating IRS Safe Harbors,” presentation with Keith Martin, partner, Norton Rose, July 28, 2022.
• “Solar Financing Tax Equity Structures,” Strafford Webinar, presentation with Keith Martin, partner, Norton Rose, November 30, 2021.
• “Renewable Energy and the New Infrastructure Bill: Opportunities, Requirements and Potential Liabilities,” Strafford Webinar, presentation with Mona Dajani, partner, Pillsbury, November 16, 2021.
• “Insiders View: Direct Investors and Tax Equity,” Novogradac 2021 Fall Renewable Energy and Environmental Tax Credits Conference, panel, November 4–5, 2021.
• “Tax Issues for Solar Energy Projects: Investment Tax Credit, Ownership Structuring, Federal and State Tax Challenges,” Strafford Webinar, presentation with Tony Grappone, partner, Novogradac and Eli M. Katz, partner, Latham & Watkins, August 11, 2021.
• “Tax Credit Insurance,” Aon Transaction Solutions Symposium, panel, February 2–4, 2021.
• “Developing and Financing California’s Energy Transition,” Pillsbury’s California CLE Marathon, presentation with Rob James, partner, Pillsbury, January 13, 2021.
• “Solar Financing Tax Equity Structures,” Strafford Webinar, presentation with Keith Martin, partner, Norton Rose, June 4, 2020.
• “Using Inverted Leases to Finance Renewable Energy Projects: Evaluating Tax Risks, Navigating Structural Variations, Leveraging Pass-Through Election,” Strafford Webinar, presentation with Keith Martin, partner, Norton Rose, February 12, 2020.
• “Tax Issues for Solar Energy Projects: Investment Tax Credit, Ownership Structuring, Federal and State Tax Challenges,” Strafford Webinar, presentation with Tony Grappone, partner, Novogradac and Eli M. Katz, partner, Latham & Watkins, July 23, 2019.
• “Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases and Partnership Flips,” Strafford Webinar, presentation with Keith Martin, partner, Norton Rose, November 29, 2018.
• “Understanding the Details of Beginning of Construction Standard and Recent Tax Controversy Trends,” 2018 Deloitte Alternative Energy Seminar, Denver, panel, August 15–17, 2018.
• “Using Partnership Flips to Finance Renewable Energy Projects: Evaluating Tax Risks, Navigating IRS Safe Harbors,” Strafford Webinar, presentation with Keith Martin, partner, Norton Rose. July 26, 2018.
• “Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases and Partnership Flips,” Strafford Webinar, presentation with Keith Martin, partner, Norton Rose. August 15, 2017.
• “Using Inverted Leases to Finance Renewable Energy Projects,” Strafford Webinar, presentation with Keith Martin, partner, Chadbourne & Parke, March 28, 2017.
• “Tax Insurance,” Aon Transaction Solutions Symposium, Las Vegas, panel, February 1–3, 2017.
• Partnership Flips Panel Discussion,” Strafford Webinar, presentation, January 26, 2017.
• “Compare and Contrast Tax Equity Structures,” SEIA Finance and Tax Seminar, Washington, DC, presentation, December 7–8, 2016.
• “Tax Controversy Trends and Changes to IRS Audits of Partnerships,” 2016 Deloitte Alternative Energy Seminar, Scottsdale, Ariz., panel, November 14–15, 2016.
• “Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases and Partnership Flips,” Strafford Webinar, presentation with Keith Martin, partner, Chadbourne & Parke, November 9, 2016.
• “Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases and Partnership Flips,” Strafford Webinar, presentation with Keith Martin, partner, Chadbourne & Parke, August 8, 2016.
• “Innovations in Energy Financing: Supporting the Transformation,” MIT Energy Conference, Cambridge, Mass., panel, March 4–5, 2016.
• “Deep Dive on Inverted Leases,” SEIA Finance and Tax Seminar, New York, N.Y., presentation, February 18–19, 2016.
• “ITC Step Down—what will be the impact on developers seeking financing in 2016 and beyond,” Distributed Solar Summit, San Diego, panel, November 17, 2015.
• “Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases and Partnership Flips,” Strafford Webinar, presentation with Keith Martin, partner, Chadbourne & Parke, October 29, 2015.
• “Solar Financing Tax Equity Structures: Sale-Leasebacks, Inverted Leases and Partnership Flips,” Strafford Webinar, presentation with Keith Martin, partner, Chadbourne & Parke, August 13, 2015.
• “Securitizing Tax Structured Assets,” Distributed Solar Summit, San Diego, panel, November 18, 2014.
• “Understanding Inverted Leases,” SEIA Finance and Tax Seminar, San Francisco, April 4, 2014.
• “Understanding Inverted Leases,” SEIA Finance and Tax Seminar, New York, N.Y., June 26, 2013.

Publications

• “Biden Administration Announces Electric Vehicle Charging Action Plan to “Fast-Track” New Infrastructure Law Investments,” Pratt’s Energy Report, Jorge Medina, Aimee P. Ghosh and Zachary C. Rozen, Volume 22, No. 3, March 2022.
• “IRS Extends Safe Harbor for Offshore Wind and Federal Land Projects,” Pratt’s Energy Report, Jorge Medina and Mona E. Dajani, Volume 21, No. 3, March 2021.
• “Tax Extenders Included in the Stimulus Bill Poised to Provide a Boost to Renewables,” Texas Lawyer, Jorge Medina and Mona Dajani, January 12, 2021.
• “Solar Financing Explained,” Greentech Media, David Lowman and Jorge Medina, January 23, 2013.
• “Tax Deductions for Film and Television Productions under Section 181,” California Tax Lawyer, Winter 2007 – Volume 16, Number 1, Jorge Medina and Patrick S. Klein.