O’Melveny Worldwide

Tax Equity Transactions 

Caroline has worked on numerous tax equity transactions during her career. A sample over the last two years include:

  • Wells Fargo in connection with over $4 billion of tax equity investments with various sponsors across the country, including its approximately $880 million investment in a portfolio of 4 wind and 1 solar project with a fair market value in excess of $1.6 billion.
  • Multiple financial institutions in tax equity investments in standalone battery energy storage projects located in California pre- and post-Inflation Reduction Act.
  • A leading financial institution in its project financing of, and preferred equity investment in, a 230 MW multi-phase solar and battery storage project in California.
  • A leading financial institution in its hybrid tax equity investments in portfolios of solar and wind projects located in Texas, Illinois, Indiana, and South Dakota.
  • A leading financial institution in its tax equity investment in two wind power projects located in Texas.
  • A leading financial institution in its staggered tax equity investment in multiple solar and energy storage projects added to a single portfolio. 

Tax Credit Transfer Agreements

  • A leading financial institution in connection with the sale of approximately $225 million of production tax credits and investment tax credits in connection with a hybrid tax equity transaction of four projects across the U.S. 
  • A leading insurance company in connection with its purchase of approximately $120 million of solar and energy storage investment tax credits.

Energy M&A and Other Transactions

  • A leading financial institution in the preferred equity investment in, and project financing of, a 75MW portfolio of commercial and industrial solar installations in various states.
  • A leading financial institution in creating a bespoke joint venture vehicle to acquire 100% of another financial institution’s portfolio of tax equity assets.
  • An energy company in connection with developing a partnership framework for designing, constructing, owning, and operating carbon capture and sequestration projects.
  • A leading financial institution on a bifurcated financing of two solar and co-located energy storage projects in California.
  • A leading financial institution on its transfer of $6 billion of investments across 44 individual transactions.
  • Entegra Power Group in the sale of a 550 MW natural gas power block and 25% interest in all related common facilities to Tucson Electric Power Company and UNS Electric, Inc.
  • Numerous financial institutions and corporations in their acquisitions and sales of tax equity investments in the secondary market.

 

Admissions

Bar Admissions

  • California
  • New York

Education

  • Columbia Law School, J.D.: Harlan Fiske Stone Scholar; Managing Editor, Columbia Law Review
  • Yale University, B.A., History: with distinction; cum laude

Professional Activities

Internships

  • Honorable Thomas M. Reavley, U.S. Court of Appeals for the Fifth Circuit