Jeffrey Davis

Partner, Washington, DC

Biography

Overview

Jeff Davis is a partner in the Tax practice in White & Case's Washington DC office. He advises clients on a wide range of US federal income tax matters, with an emphasis on project finance, development and energy transactions.

Jeff has a particular focus on transactions involving renewable energy projects, including tax equity financings (such as flip partnerships and leases), mergers and acquisitions (including portfolios), backleverage financings, tax credits (including the production tax credit provided under IRC section 45, the investment tax credit provided under IRC section 48, and credits for electric vehicles under IRC sections 30D and 45W) and other incentives such as depreciation. He has experience with a wide range of renewable energy resources, including wind, solar, fuel cells, geothermal, hydroelectric, biomass and refined coal.

In addition, Jeff represents clients in matters before the US Department of the Treasury and the Internal Revenue Service, including assisting with applications for private letter rulings and requests for published guidance. He frequently speaks at conferences on topics of interest to the renewable energy industry. He also has served as an adjunct professor in the graduate tax program at Georgetown University Law Center.

Jeff was named to A Word About Wind's "Legal Power List 2022", which is the 100 most influential lawyers working on the financial side of the wind industry. He has been ranked by Chambers USA and Chambers Global in 2019-2022 in Projects: Renewables & Alternative Energy. Chambers stated that he is "'[V]ery diligent and experienced' in the renewables sector . . . [and] known for his expertise in tax equity matters". Chambers also noted that "He's very thorough and very knowledgeable on all aspects of tax" and "He is very detail-oriented and very careful in his analysis." And that "He is super technical". In December 2022, Jeff was recognized by Northern Virginia Magazine as a Top Lawyer (Tax Law). In December 2018, for the second year in a row, Washingtonian Magazine named Jeff a Top Lawyer (Tax).

Bars and Courts
District of Columbia Bar
US Supreme Court
US Court of Appeals for the Sixth Circuit
US Tax Court
Education
LLM
Taxation
Georgetown University Law Center
JD
Pepperdine University School of Law

Rick J. Caruso

BS
Lipscomb University
Languages
English

Experience

Tax Equity Financings*

  • Represented a food and beverage company in making a tax equity investment in a 152 megawatt solar project in Texas
  • Represented a financial services company in providing tax equity for a 224 megawatt solar project plus 448 megawatts of co-located battery storage
  • Represented a renewable energy company in the tax equity financing of a 54 megawatt wind project in Illinois
  • Advised a bank in connection with its commitment to provide tax equity for an offshore wind project
  • Represented a renewable energy company in the tax equity financing of an 80 megawatt wind project in Illinois
  • Represented a financial services group in providing tax equity for a portfolio of fuel cell projects
  • Represented a leading U.S. tax equity investor in making a tax equity investment in a 160 megawatt wind project in Texas
  • Represented a food and beverage company in making a tax equity investment in a 250 megawatt solar project in Texas
  • Represented a bank in providing tax equity for a portfolio of fuel cell projects
  • Represented a leading financial institution in making three separate tax equity investments in portfolios of community solar projects
  • Represented a bank in making a tax equity investment in a portfolio of residential solar projects
  • Represented a renewable energy company in the tax equity financing of a 76 megawatt wind project in Illinois
  • Advised a leading U.S. tax equity investor in making a tax equity investment in the first offshore wind project in the U.S.
  • Represented a leading U.S. tax equity investor in making a tax equity investment in a 98 megawatt wind project in Illinois
  • Represented a renewable energy company in the tax equity financing of a 145 megawatt solar project in Colorado
  • Represented an insurance company in providing tax equity to various solar projects

Debt Financings*

  • Represented a renewable energy company in the construction financing of a 54 megawatt wind project in Illinois
  • Represented a renewable energy company in the construction financing of a 274 megawatt portfolio of solar projects in California
  • Represented the lenders in providing construction loans for a portfolio of solar projects
  • Represented the lenders in providing backleverage financing for a portfolio of residential solar projects

M&A*

  • Represented an insurance company and an infrastructure-focused private equity fund in the acquisition of a minority interest in a 1.2 gigawatt portfolio of wind and solar projects from the nonregulated unit of an energy holding company
  • Represented an infrastructure fund the acquisition of minority stake in a renewable energy company that develops, owns and operates utility-scale wind, solar, energy storage and geothermal generation assets
  • Represented an energy infrastructure company in the acquisition of a portfolio of early-development stage solar projects in Tennessee
  • Represented an insurance company in the acquisition of a minority interest in an independent power producer with a portfolio of over 4 gigawatts of solar and battery storage systems that are contracted, under construction, or operating across the U.S. and Canada
  • Advised an energy infrastructure company in its bid to acquire a developer, owner and operator of commercial and industrial solar projects
  • Advised an energy infrastructure company in its bid to acquire a solar energy developer, operator, and EPC contractor

Other*

  • Advised a renewable energy developer regarding the qualification of solar projects for investment tax credits
  • Represented a developer in negotiated supply contracts for a carbon capture project
  • Advised an energy infrastructure company in establishing a solar development platform
  • Advised a renewable energy company regarding the beginning of construction of various wind and solar projects
  • Advised an autonomous vehicle company regarding qualification of electric vehicles for tax credits
  • Advised an energy infrastructure company regarding procurement of equipment to begin construction of numerous solar projects
  • Represented the lenders in safe harbor equipment supply loans for solar projects
  • Advised a transportation solutions company regarding qualification of electric vehicles for tax credits

*Matters prior to joining White & Case

Awards and Recognition

"Legal Power List", A Word About Wind 2022

Chambers USA and Chambers Global in 2019-2022 in Projects: Renewables & Alternative Energy. 

Top Lawyer (Tax Law), Northern Virginia Magazine, 2022

Top Lawyer (Tax), Washingtonian Magazine 2017-2018