Overview
Zack Taylor focuses his practice on the development, financing, and acquisition of renewable and alternative energy projects. He represents developers, independent power producers (IPPs), and utility-scale investors in complex transactional matters, including project mergers and acquisitions, tax equity financing, and debt structuring. His experience spans a diverse portfolio of assets, including utility-scale solar and wind, battery energy storage systems (BESS), renewable natural gas (RNG), and clean hydrogen infrastructure.
Zack advises clients through the full project lifecycle, with a particular emphasis on negotiating the construction and procurement agreements essential to large-scale infrastructure bankability. His work includes drafting and negotiating Engineering, Procurement, and Construction (EPC), Balance of Plant (BOP), Build-Transfer (BTA), and Operation and Maintenance (O&M) agreements. He also manages equipment procurement and complex supply-chain risk through the negotiation of Turbine Supply (TSA) and Module Supply (MSA) agreements, including the strategic transfer of physical work components to establish the commencement of construction for tax purposes, while also focusing on international trade compliance, tariff mitigation strategies, and Foreign Entity of Concern (FEOC) restrictions.
Beyond procurement and finance, Zack executes project-level due diligence regarding site control, land rights, and regulatory compliance. He maintains a sophisticated understanding of the technical and financial intersections between the Inflation Reduction Act (IRA) and the One Big Beautiful Bill Act (OBBBA). His practice includes providing strategic counsel on complex tax credit monetization and transferability structures, with a specific focus on navigating the rigorous Domestic Content (DC) procurement standards and Prevailing Wage and Apprenticeship (PWA) mandates required for maximum credit capture. Additionally, Zack guides international investors through the regulatory landscape of cross-border transactions, including CFIUS filings, AFIDA disclosures, and BEA reporting.
Before joining Stoel Rives, Zack practiced at an Am Law 200 law firm in Minneapolis. While attending law school, he was a student director of the Ronald M. Mankoff Tax Clinic at the University of Minnesota Law School and a judicial extern to the Honorable Susan Nelson of the U.S. District Court for the District of Minnesota.
Zack served in United States Army from 2007 to 2020. During that time, he served as the deputy commander for Special Operations Forces in Northern Afghanistan, leading multinational teams and coordinating complex, high-risk operations, receiving numerous military awards, including the Bronze Star Medal, Meritorious Service Medal, and Combat Action Badge.
Education
University of Minnesota Law School, J.D., 2023, cum laude; editor-in-chief, Minnesota Journal of International Law
United States Military Academy, B.S., Economics; Electrical Engineering track, 2014; Dean’s List
Admissions
Minnesota
Experience
Project Development & Construction
- Represented a Fortune 500 regulated utility in the strategic acquisition of early-stage solar assets via Asset Purchase Agreements (APA); managed the complex transfer of physical work components and procurement of critical equipment to formally establish the commencement of construction for tax credit purposes.
- Leveraged an electrical engineering background to conduct detailed technical specification analysis for a utility-scale combined-cycle combustion turbine (CCCT) project; ensured the primary Engineering, Procurement, and Construction (EPC) Agreement was contractually aligned with performance guarantees, thermal efficiency standards, and interconnection requirements.
- Drafted and negotiated specialized Turbine Supply Agreements (TSA) and Module Supply Agreements (MSA) for safe harbor purposes, applying technical knowledge of equipment lead times and manufacturing cycles to ensure project eligibility for maximum tax credit percentages.
- Advised a multi-member municipal power agency on numerous project acquisitions and the negotiation of complex commercial agreements related to portfolio expansion and regional power supply.
- Supported a subsidiary of a Fortune 250 environmental services and waste-to-energy company in the development of a multi-project RNG portfolio, managing the standardized drafting of NASEB-based procurement and offtake agreements for dozens of utility-scale facilities.
- Advised on the development, acquisition, and repowering of utility-scale solar and wind projects with an aggregate value exceeding $1 billion, focusing on the negotiation of repowering agreements, Turbine Supply Agreements (TSA), Module Supply Agreements (MSA), Engineering, Procurement, and Construction (EPC), and Operation and Maintenance (O&M) agreements.
- Executed comprehensive, project-level due diligence for large-scale energy infrastructure, conducting high-stakes risk assessments of land rights, severed mineral interests, and environmental permitting to ensure project bankability and long-term operational viability.
Supply Chain & International Trade Compliance
- Negotiated tier-one TSAs and MSAs across a diverse portfolio of wind and solar assets, incorporating provisions to mitigate risks associated with U.S. tariff policy uncertainty and rapid shifts in trade enforcement.
- Provided counsel on complex domestic sourcing mandates, including the technical procurement requirements of the One Big Beautiful Bill Act (OBBBA) and Domestic Content (DC) bonus criteria under the Inflation Reduction Act.
- Guided clients through international trade compliance matters and Foreign Entity of Concern (FEOC) restrictions to mitigate port-to-project supply chain risks.
Finance, Tax Equity & Regulatory
- Assisted sponsors and investors in navigating the evolving tax credit monetization and transferability provisions of the Inflation Reduction Act (IRA) and the One Big Beautiful Bill Act (OBBBA).
- Conducted eligibility analysis for the Energy Community Tax Credit Adder, evaluating statistical area data and brownfield status to optimize project economics under the Inflation Reduction Act.
- Advised on Prevailing Wage and Apprenticeship (PWA) compliance and Domestic Content (DC) bonus criteria to ensure maximum credit capture and financial bankability.
- Supported the tax equity financing for a 200 MW solar plus storage project, advising on credit support terms and financial modeling assumptions.
- Assisted international investors with federal regulatory disclosures and filings, including CFIUS, AFIDA, and BEA reporting.
- Advised on the impact of the Corporate Transparency Act (CTA) on energy project ownership and reporting structures.
Insights
Insights & Presentations
- Quoted in “New Treasury Beneficial Ownership Rule Defangs Transparency Law,” Bloomberg Law, March 25, 2025
- “Corporate Transparency Act’s Wild Ride Shows No Sign of Slowing,” Bloomberg Law, March 12, 2025
- Quoted in “Trump Signals Regulatory Move Against Corporate Transparency Act,” Bloomberg Law, March 3, 2025
- Speaking Engagement: “Corporate Transparency Act (CTA) Update,” Venture Capital: 2024 Review and 2025 Outlook, December 2024
- Webinar: “Complying with the Corporate Transparency Act,” October 1, 2024
- “CTA Ruling Poses Uncertain Future for States With Similar Laws,”” Bloomberg Law, March 12, 2024
- “KC lawyers: Despite federal ruling, don't ignore Corporate Transparency Act,” Kansas City Business Journal, March 11, 2024
- Quoted in “Introducing the ‘Corporate Transparency Act’,” Minnesota Lawyer, January 17, 2024
- Featured in “Breaking the Ice: Advising leaders on battlefield, in business,” Minnesota Lawyer, February 23, 2024
Affiliations
Civic
- VITA Tax Preparer
- City Council Campaign Treasurer
- Service 2 School Ambassador