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Ben Livni
Ben Livni
Senior Associate — Tax
E: blivni@velaw.com T: +1.213.527.6414
VCard BIO PDF
Senior Associate — Tax

Ben Livni

Ben Livni
Los Angeles
T: +1.213.527.6414
F: +1.213.402.2138

Two California Plaza
350 South Grand Avenue
Suite 2100
Los Angeles, California 90071

E: blivni@velaw.com
VCard BIO PDF
Ben Livni

Ben’s practice focuses on tax matters related to asset finance, with an emphasis on renewable energy, zero carbon, and infrastructure assets. Ben has experience utilizing a variety of structures in the finance, disposition, acquisition, and development of clean energy projects including solar, wind, energy storage, carbon sequestration, and hydrogen. Ben also advises clients more broadly in connection with tax issues related to capital markets and derivative products, M&A and private equity, and reorganization and bankruptcy.

In the course of his practice, Ben regularly represents Fortune 50 companies, investors, utilities, sponsors, and developers in the clean energy space.

Experience Highlights

  • Swift Current in the construction debt and tax equity financing of a 195 MW solar project in Texas

  • Tax equity investor in its investment in a 65 MW solar project in North Carolina

  • Major financial institution in an approximately $100 million tax equity investment in a 200 MW solar energy generation facility located in Randolph County, Indiana.  The project will be operated by a market leading global renewable energy developer and its affiliates, and will sell power and environmental attributes to an electricity supply cooperative pursuant to a long-term power purchase agreement

  • Wells Fargo in their tax equity investment to construct the 145 MW Aragonne Mesa Wind Project and to repower the 90 MW Aragonne Wind Project, both in Guadalupe County, New Mexico

  • Financial sponsor in partnership flip tax equity financing in respect of a portfolio of C&I solar photovoltaic (PV) projects

  • Financial sponsor in the sale leaseback financing of a portfolio of commercial and industrial (C&I) solar photovoltaic projects in Minnesota

  • Tax equity investor in its approximately $320 million commitment to a portfolio of two solar projects in Arizona and Virginia totaling 355 MW and including 100 MW of storage, representing one of the first tax equity financings of a battery energy storage asset for this investor

  • Apollo Global Management in connection with its $175 million strategic investment in Summit Ridge Energy, a leading owner-operator of community solar assets

  • Tax equity investor in their investment in two solar projects with 450 MW combined capacity in California

  • Tax equity investor in the financing of 8 solar facilities in New York with aggregated capacity of 215.8 MWdc

  • MN8 Energy in the acquisition and tax equity financing of the 150 MW solar-plus-storage High Desert Solar Project in San Bernardino County, California

  • Major financial institution in an approximately $142 million tax equity investment in the re-powering of a 162.2 MW wind project located in Caddo and Kiowa Counties, Oklahoma; the re-powered project will be operated by a market leading wind energy developer, and its affiliates, and will sell power and environmental attributes pursuant to a long-term power purchase agreement with an off-taker located in a different regional power market

  • Tax equity investor in the financing of 239 MW and 200.2 MW wind projects in Texas and a 148.4 MW wind facility in Oklahoma

  • Terra-Gen in the approximately $270 million construction financing and $136 million tax equity financing for the 64.5 MW Tehachapi Plains, 60.3 MW Oasis Power, and 14.4 MW Oasis Alta wind generation facilities in Kern County, California, and the 61.2 MW Coachella and 46.8 MW Painted Hills wind generation facilities in Riverside County, California

  • UK-based investor in a joint venture exploring numerous CCS/CCUS projects on the Gulf Coast (ongoing)

  • LSB Industries in its agreement with Lapis Energy for the development of a project to capture and permanently sequester CO2 from ammonia production at LSB’s El Dorado, Arkansas facility

  • Blackstone Credit and ClearGen, a Blackstone Credit portfolio company, in the formation of a strategic partnership between ClearGen and GreenStruxure, a Schneider Electric and Huck Capital joint venture, to develop, own and operate up to $500 million of renewable energy microgrid systems for C&I customers

  • Representing a lender in providing debt financing to a leading developer of dairy digesters for generating renewable vehicle fuel and the monetization of Section 45Z Clean Fuel tax credits

  • Various sponsors and developers in domestic content and energy community qualification analysis and preparation of related tax opinions and memorandums

  • Negotiation of tax insurance policies covering tax risks relating to the Inflation Reduction Act

  • Preparation of comments to Treasury and other stakeholder comments relating to various Inflation Reduction Act matters on behalf of investors, sponsors, developers, and trade associations

Credentials

  • Loyola Law School, J.D. cum laude, 2018 (Los Angeles Law Review, Production Editor; Order of the Coif; Winner, Student Writing Competition, Tax Notes)
  • University of California, Santa Barbara, B.A. Economics and Accounting, 2014
  • Judicial extern to The Honorable Victoria Kaufman, U.S. Bankruptcy Court for the Central District of California
  • Extern, U.S. Securities and Exchange Commission
  • Member: American Bar Association Tax Section
  • California
  • Hebrew (fluent)
  • “Guide to Energy Tax Credits: The Basics to Fuel, Power, and Carbon Capture Credits,” D.C. Bar Association, May 24, 2022 (co-speaker)
  • “Getting Charged Up: A Primer on Energy Tax Incentives,” ABA Midyear Tax Meeting, February 1, 2022 (panelist)
  • “COVID Relief Bill Contains Energy Tax Extenders,” client alert, December 22, 2020 (co-author)
  • “IRS Extends Safe Harbor for Renewable Energy Projects,” client alert, May 28, 2020 (co-author)
  • “The Storm of Cloud Computing Taxation,” State Tax Notes, July 2017 (author)

News & Insights

Deals & Cases
8 Rivers Announces Cormorant Clean Energy Project, the First Commercial Deployment of 8RH2 Ultra-Low Carbon Hydrogen Technology
January 10, 2024
Insight
Treasury Issues Proposed Regulations on 45X Advanced Manufacturing Production Credit

V&E Inflation Reduction Act of 2022 Update

Inflation Reduction ActEnergy Transition
December 18, 2023
Insight
Treasury Releases a Swath of Guidance on the Investment Tax Credit

V&E Inflation Reduction Act of 2022 Update

Energy TransitionInflation Reduction ActManaging the Modern Workplace
November 21, 2023
Insight
Treasury Issues Proposed Regulations for IRA Labor Requirements

V&E IRA Update

Energy TransitionInflation Reduction ActManaging the Modern Workplace
September 5, 2023