Sidley has decades of experience representing major banks, corporations, insurance companies, and other institutions in making, syndicating, buying, and selling debt and equity investments in affordable housing developments that generate low income housing tax credits and historic rehabilitation tax credits under the Internal Revenue Code. Sidley’s extensive industry experience and combined knowledge of partnership, securities, tax, finance, and real estate law positions us to provide comprehensive and practical advice on all aspects of the complex debt, equity, and real estate structures that are utilized in such transactions, including transactions featuring multiple debt providers, tax-exempt bond financing, public-private partnerships, and government loan and rental subsidy programs.
We represent developers and financial institutions on many of the most significant renewable electric generation projects in the United States and around the world, and provide comprehensive advice on all aspects of those transactions, including tax. Because of the important role played by tax incentives (most notably production and investment tax credits) in financing these projects, our tax lawyers work closely with project finance/energy attorneys to develop complex partnership, lease, and other transaction structures that allow for the most efficient utilization of those incentives by our clients.
Sidley has been at the forefront of opportunity zone transactions, including advising one of the first qualified opportunity funds to launch in 2018. We provide structural and transactional advice on opportunity zone deals to investment banks, fund managers, family offices, high net worth individuals, property owners, and fund managers with respect to single asset, multiple assets, blind pool, parallel, combined, and other types of funds investing not only in real estate projects but also in other operating businesses. We also advise on transactions that involve twinning opportunity zone benefits with other tax benefits such as new markets tax benefits, low income housing tax credits, and brownfields tax credits and incentives. Combining our extensive tax experience with Sidley’s funds, securities law, real estate, and transactional practices, we are able to provide our clients with practical advice on how best to implement their capital raising and investment strategies. Dan Altman, a partner in our Tax practice, has been recognized in 2019 and 2020 by Opportunity Zone Magazine as one of the “Top 25 Opportunity Zone Influencers” in the country.