Richard Wright

Partner

Areas of Focus

Richard Wright

Partner

rwright@akingump.com

Areas of Focus

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Biography
  • Advises on the tax aspects of tax equity transactions, including sale-leaseback, partnership “flip” transactions and back-leverage loan transactions.
  • Extensive tax credit transfer experience in the renewable energy and energy transition space.
  • Renders tax advice with respect to the acquisition and sale of interests in general partnerships, corporations and limited liability companies.
  • Significant aircraft finance experience and regularly advises U.S. and non-U.S. clients with respect to aircraft lease and finance transactions.

Richard’s practice focuses on the tax aspects of complex, high-dollar transactions in the renewable energy space. He regularly provides advice to investors and developers regarding start of construction matters, prevailing wage and apprenticeship compliance, placement in service issues and energy credit, production tax credit and other tax credit qualification issues. Richard counsels investors and developers regarding transfers of tax credits related to solar, wind, energy storage, fuel cell and renewable natural gas projects. He also provides advice on structuring investments in, and arranging for the disposition of, renewable energy assets, natural gas-fired power plants, data centers and other assets.

He has more than two decades of experience advising investors and developers in sale-leaseback transactions involving renewable energy projects and other assets, and he has co-authored a Bloomberg Tax Management Portfolio on the topic, entitled “Equipment Leasing: Tax Principles and Structuring.”

Richard regularly advises clients seeking investments in aircraft or aircraft engines, structured using a lease, loan or hybrid financing arrangement.

Representative Work
  • Represented Republic Services Renewable Energy in connection with its investments in ITC-eligible solar energy projects, wind energy projects, battery energy storage projects and solar energy and battery energy storage combination projects, structured using a partnership flip structure, such as a 50 MW (ac) solar energy system that is linked with a 25 MW (ac) battery energy storage system in San Bernardino County, California, a 216 MW (ac) wind energy project in Coconino and Navajo Counties, Arizona, a 30 MW (ac) solar energy system that is linked with a 30 MW (ac) battery energy storage system in Oahu, Hawaii, a 120 MW (ac) solar energy system that is linked with a 480 MWh battery energy storage system in Maricopa County, Arizona and a 100 MW (ac) solar energy system in Pinal County, Arizona.
  • Represent Jane Street Capital in connection with its acquisition of energy tax credits from project developers and tax equity partnerships, including the acquisition of $135,000,000 in energy tax credits related to qualified fuel cell property owned by a partnership whose members are a tax equity investor and a subsidiary of Generate Capital, $102,295,473.67 in energy tax credits related to a solar energy project owned by a partnership whose members are a tax equity investor and a subsidiary of SB Energy Global and $50,000,000 in energy tax credits related to a battery energy storage project owned by a partnership whose members are a tax equity investor and a subsidiary of Clearway Energy.
  • Represent BP Alternative Energy North America in connection with its sale of energy tax credits, including energy tax credits related to a 107 MW (ac) solar energy system that is in Fulton County, Ohio.
  • Represented First Horizon Bank, Pacific Western Bank and Regions Bank in connection with their acquisition of undivided interests in two solar projects in Georgia valued at $375 million and structured using a sale-leaseback transaction.
  • Represented Regions Bank in connection with a $300 million single investor master tax lease financing for a portfolio of solar projects in the United States.
  • Represented Regions Bank in connection with its acquisition and leaseback of a 20 MW (ac) solar energy system that is linked with a 20 MW (ac) battery energy storage system in Cochise County, Arizona.
  • Represented two investors in connection with their acquisition of undivided interests in a solar project in Kentucky valued at $500 million and structured using a sale-leaseback transaction.
  • Represented The Huntington National Bank in connection with its acquisition of three repowered, domestic content ITC-eligible, wind energy projects that are located in Minnesota and Iowa and valued at approximately $380 million, which it acquired from Greenbacker Renewable Energy Corporation using a sale-leaseback structure.
  • Represent lenders and sponsors in connection with convertible construction to term debt and back leverage debt related to investments in solar energy projects and battery energy storage projects. 
  • Represented GoodFinch in connection with its acquisition of securities backed by solar energy projects from SunPower Capital Services, LLC during the course of Chapter 11 bankruptcy proceedings.
  • Represented GoodFinch in connection with its acquisition of the equity interests owned by a subsidiary of OYA Renewables Corporation in a tax equity partnership whose assets are community solar projects in New York State.
  • Advised I Squared Capital on the tax aspects of its $1.2 billion acquisition from Duke Energy of a portfolio of hydroelectric and natural gas generation plants, transmission infrastructure and natural gas processing facilities, totaling 2,300 MW, in Peru, Chile, Ecuador, Guatemala, El Salvador and Argentina.
  • Advised DHL Aviation (Americas) Inc. and its affiliates with respect to the U.S. federal income tax consequences of finance lease transactions entered into by members of the DHL Aviation group.
  • Advised DHL Aviation (Americas) Inc. with respect to the JOLCO financing of three new Boeing 777F aircraft.
  • Advised LATAM Airlines with respect to the refinancing of thirty-two Boeing 767-316F aircraft entered into by a subsidiary of LATAM Airlines and a consortium of lenders.

List may include matters worked on prior to joining Akin.

Education
  • LL.M., New York University School of Law, 2003

  • J.D., Brooklyn Law School, 1998

  • B.A., Boston College, summa cum laude, 1995

Bar Admissions
  • New York

Recognitions
  • Lawdragon, 500 Leading Global Tax Lawyers, 2025.
  • The Legal 500 US, US Taxes: Non-Contentious and Recommended Lawyer, 2024.

Insights and Achievements

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