Experience

Cooperatives

Advises exempt and non-exempt cooperatives on organizational, operational, and transactional aspects of cooperative tax law, including restructuring issues and maintenance of tax-exempt status.

• Tax planning for cooperative asset sale and conversion to a limited liability company
• Tax planning for the tax-free merger of two agricultural producer cooperatives
• Tax and corporate planning for the tax-free restructuring of an agricultural supply cooperative’s base capital plan
• Advised and prepared tax documents for the organization of a state-law cooperative taxed as a partnership for federal income tax purposes
• Analyzed patronage and nonpatronage income issues for Section 521 cooperatives
• Tax planning for consolidation of multiple supply cooperatives
• Prepare documents and provide advice regarding formation of new cooperatives, including agricultural supply and producer cooperatives, cooperative grocers, and worker cooperatives

Renewable Energy

Assists energy developers, owners and investors qualify for federal, state and local tax incentives and implements transaction structures that maximize the value of those incentives. Works on wind, solar, geothermal, municipal solid waste, biomass, and other renewable energy projects. Counsels oil and gas companies on issues relating to cost and percentage depletion and IDCs.

• Tax equity structuring for development of municipal solid waste and biomass renewable energy facility
• Tax equity structuring for development of solar and wind facilities
• Analyze state income, property, sales and use, and transfer tax issues related to renewable energy project development
• Prepare California state property tax filings for change in ownership of renewable energy facilities
• Private letter ruling request for renewable energy facilities
• Tax due diligence in renewable energy project financings and acquisitions
• Section 1603 Grant application, qualification, and dispute resolution

General Tax Advice and Transactions

Advises clients on entity formation, corporate mergers and acquisitions, transactions involving partnerships, S corporations, limited liability companies and other pass-through entities, tax aspects of compensation arrangements, and tax controversy matters. Counsels companies and individuals on estate and gift taxes, employment taxes and international taxation.

• Tax withholding obligations and FATCA compliance
• S corporation stock sale and 336(e) election
• Employment tax withholding and alternative employee compensation

Honors & Activities

• Member, Tax Section, American Bar Association
• Member, Tax Section, Minnesota State Bar Association
• Member, Hennepin County Bar Association

Insights & Presentations

• Presenter, “Working with Cooperatives in Wisconsin—2020,” Wisconsin Center for Cooperatives and UW Law and Entrepreneurship Webinar, June 18, 2020
• Author, “Understanding the Tax Impact of Federal COVID-19 Relief Laws,” Bench & Bar of Minnesota, May 27, 2020
• Presenter, “Introduction to Cooperative Patronage and Financing of Cooperative Operations,” Client Presentation, Viroqua, Wisconsin, December 16, 2019
• Moderator, “Solar Finance for Residential & Commercial Developers: Delivering Options for your Customer Base and Business Health,” Gateway to Solar, MnSEIA, October 21, 2019
• Presenter, “Choice of Business Entity after Tax Reform: Re-Evaluating the Best Option,” Minnesota CLE, May 6, 2019
• Co-chair and presenter, “Business and Personal Tax Planning: The Impact of the ‘Tax Cuts and Jobs Act’ and other New Tax Developments,” Minnesota CLE, February 26, 2019
• Coauthor, “Structuring the Transaction: Tax Considerations,” 2018 edition, in Advising Oregon Businesses, Oregon State Bar Association
• Presenter, “Choice of Entity: The New Landscape!, Important Tax Considerations for Entities and Owners,” Minnesota CLE, October 24, 2018
• Coauthor, “Solar Developers Must be Mindful of Looming ITC Deadlines,” Solar Industry, September 20, 2018
• Coauthor, “With PTC Deadlines Looming, Could Wind Catcher Cancellation be Part of a Trend?,” North American Windpower, September 13, 2018
• Presenter, “Choice of Business Entity After Tax Reform: Re-Evaluating the Best Option,” Minnesota CLE, May 7, 2018
• Panelist, “Piecing it Together: Trump’s Tax Reform and Project Finance,” Midwest Solar Expo & Smart Energy Symposium, May 1, 2018
• Presenter, “Energy Project Depreciation and Tax Credits Under the New Tax Bill,” Webinar, March 16, 2018
• Moderator, “The New Federal Tax Law,” Minnesota CLE, March 2, 2018
• Presenter, “Business Topics in the New Federal Tax Law,” Minnesota CLE, February 15, 2018
• Coauthor, “Bloomberg BNA Tax and Accounting: Minnesota Corporate Income Tax Navigator,” 2016-2017
• Coauthor, “Tax Issues,” Chapter 8, The Law of Solar Energy: A Guide to Business and Legal Issues, Stoel Rives LLP, Fifth Edition, 2017
• Panelist, “What to Expect – Your First Three Years Practicing Tax Law,” Mitchell Hamline College of Law, October 27, 2016
• Contributor, Stoel Rives Climate Policy, Renewable Energy, & Sustainability Blog
• Speaker, “Amendments to Partnership Audit Provisions,” Stoel Rives LLP, December 3, 2015
• Coauthor, “Understanding the Yieldco Structure for Renewable Energy Project Finance,” Renewable Energy World Magazine, May/June 2015
• “Solar Energy in Minnesota,” Client Presentation, February 24, 2015
• “Tax Considerations in Developing and Financing Community Solar Gardens” (arranged presentation), Stoel Rives 2014 Master Seminar: Solar Energy in Minnesota, October 7, 2014
• “Treasury and IRS Updates,” Stoel Rives LLP, ongoing monthly presentations

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