Kevin T. Pearson

Kevin is a partner and the chair of the firm’s Executive Committee. His practice focuses principally on federal income tax law, including both transactional matters and tax controversy matters. As part of his transactional practice, Kevin regularly advises clients regarding all aspects of corporate taxation, including taxable and tax-free mergers and acquisitions, debt and equity offerings and other corporate finance transactions, consolidated return issues, and general corporate tax issues. He also regularly represents clients with respect to partnership, S corporation, and limited liability company transactions and tax issues, as well as choice-of-entity issues, tax accounting issues, and general tax planning issues. Kevin frequently represents clients in renewable energy financing transactions, particularly those involving the federal production and investment tax credits. In addition, Kevin advises both taxable and tax-exempt healthcare clients with respect to all types of tax, business, and financial matters. As part of his tax controversy practice, Kevin regularly represents taxpayers in IRS audits and administrative appeals, deficiency litigation in the United States Tax Court, and refund litigation in United States District Courts and the United States Court of Federal Claims.

Education

Georgetown University Law Center, LL.M., Taxation, 1998

Gonzaga University School of Law, J.D., 1996, summa cum laude; Articles Editor, Gonzaga Law Review, 1995-1996; National Moot Court

Linfield College, B.S., 1992

Admissions

Oregon

Washington

United States Court of Federal Claims

United States Tax Court

• Represented Aypa in securing a $1.5 billion construction warehouse revolving credit facility, with an additional $500 million accordion feature. This substantial financing will be used to accelerate development of utility-scale energy storage projects, serving as Aypa's principal funding source for projects expected to reach commercial operation through 2028. 
• Represented Tumac Lumber Co., Inc., in its sale of Disdero Lumber Co., LLC, a distributor of premium specialty wood products, to BlueLinx Holdings Inc. and in its sale of Specialty Wood Products, Inc., a specialty dealer of premium decking, siding, trim, heavy timber products, and other architectural-grade building materials, to SRS Distribution Inc.
• Represented Adapture Renewables, a leading U.S. solar and storage developer, in securing $321 million in debt financing from MUFG for the development of a 441 MW portfolio of solar projects in Arkansas and Illinois. The portfolio, known as Titanium, includes three projects and is Adapture’s largest to date. Financing is structured as a construction line and a tax credit bridge loan.
• Represented Copia Power in closing an $890 million tax equity commitment for its Maricopa Energy Center solar and storage facility. Expected to reach commercial operation in 2026-2027, the 550 MW solar / 2,200 MWh battery energy storage facility will be the largest solar-plus-storage project in Arizona.
• Advised ContourGlobal on its acquisition of a two-phase hybrid solar-plus-extended duration storage project located in Arizona. The project is in an advanced stage, with a combined capacity of 567 MWp of solar PV and 321 MW / 1.3 GWh of BESS, totaling 888 MW of hybrid capacity once fully built. 
• Represented NW Natural Holding Company in its acquisition of SiEnergy Operating, LLC, from SiEnergy Capital Partners, LLC, an affiliate of Ridgewood Infrastructure. SiEnergy is a natural gas distribution utility that serves approximately 70,000 customers in the greater metropolitan areas of Houston, Dallas, and Austin, Texas. 
• Represented Pine Gate Renewables, LLC, in closing $288 million in preferred equity financing, which will be used to support construction and operation of six solar projects in Alabama and Texas with total capacity of 225 MWdc, and in executing solar investment tax credit transfer agreements for the portfolio with two separate corporate buyers.
• Represented Pivot Energy in closing a $450 million debt warehouse facility, which, together with a structured equity investment from HA Sustainable Infrastructure Capital, Inc., in a new project joint venture, will support the construction of 300 MWdc of distributed generation located across California, Colorado, Delaware, Hawaii, Illinois, Maryland, Minnesota, New York, and Virginia.
• Represented Vikings Energy Farm LLC and Vikings Energy HoldCo, LLC in connection with (a) the debt financing of Vikings Energy Farm LLC’s development of a 157MWac solar photovoltaic generating facility and a 150 MW / 600MWh battery energy storage system located in Imperial County, California, and (b) the sale by Vikings Energy HoldCo, LLC of the investment tax credits and production tax credits generated by the Project to JPMorgan Chase Bank, N.A. The deal was awarded Renewables Deal of the Year by IJGlobal and was recognized as one of the first utility-scale solar-plus-storage ITC and PTC transferability transactions to close under the Inflation Reduction Act.

• Represented Altus Power, a leading developer, owner, and operator of distributed solar energy systems in the United States, in its approximately $118 million acquisition from Vitol of an 84 MW portfolio of commercial-scale solar arrays in the U.S. Northeast. The portfolio will provide electricity to approximately 2,000 community solar subscribers and serve 20 municipal, education, and enterprise customers.
• Represented Arevon Energy, Inc., in closing financing for the 200 MW / 800 MWh Condor Energy Storage Project in Grand Terrace, California, which began operations in the second quarter of 2024. The financing consisted of a complex interplay of a preferred equity investment, a construction-to-permanent back-leverage debt financing, and two side-by-side tax credit purchase transactions.
• Represented Copia Power in securing a $1.2 billion construction-to-term loan financing that will be used to fund the construction of the Harquahala Sun 1 and Harquahala Sun 2 projects, which will annually produce 450 MW of solar power and include a 300 MW / 1,200 MWh battery energy storage system. The projects—the first two phases of Copia Power’s Harquahala Sun complex—are expected to be completed in early 2025.
• Acted as legal advisor to NuScale Power, LLC, in completing its business combination agreement with Spring Valley Acquisition Corp., a publicly traded special purpose acquisition company (SPAC). The expected approximate enterprise value of the business combination of $1.9 billion will provide capital for NuScale to scale and accelerate the commercialization of its small modular reactor technology.
• Acted as legal advisor to Advantest Corporation in completing an agreement for its acquisition of R&D Altanova, Inc.
• Represented Consumer Cellular, Inc., a provider of postpaid wireless services, in its sale to GTCR, a private equity firm. Valued at a reported $2.3 billion, the deal was the largest reported M&A transaction in Oregon since 2016.

Client Successes

News

Speaking Engagements

Publications

Press Releases

Special Reports

• Selected by Chambers Global as one of “America’s Leading Lawyers for Business” (USA) for Projects: Renewables & Alternative Energy, 2022–present
• Selected by Chambers USA as one of “America’s Leading Lawyers for Business” (USA—Nationwide) for Projects: Renewables & Alternative Energy, 2021–present
• Included in The Best Lawyers in America^® (Energy Law, Tax Law), 2013–present

• Listed in The Lawdragon 500 Leading Global Tax Lawyers, 2025–present

• Listed among Rising Stars^SM by Oregon Super Lawyers^® (Tax), 2008–2009

Professional

• American College of Tax Counsel, Fellow
• American Bar Association, Tax Section, Member
• Washington State Bar Association, Tax and Business Law Sections, Member
• Oregon State Bar, Tax Section, Member
• Multnomah Bar Association, Portland Tax Litigation Club, Member

Civic

• Linfield College Alumni Association, former Board Member