McGuireWoods tax lawyers Barbara de Marigny and Durham McCormick co-wrote an article discussing the development and fate of a structure intended to allow Sol-Wind Renewable Power L.P. to access the capital it needed to acquire interests in solar- and wind-power assets. They describe the structure as a master limited partnership (MLP) on top of a “yieldco,” with the latter a necessary component because an MLP cannot invest directly in renewable energy to any substantial degree without being taxed as a corporation. Although a creative solution, they say, it didn’t negate other business fundamentals that may have discouraged investor interest in the public offering, which was postponed. Subscribers can read the full text of the article at www.nationallawjournal.com.
