Infocast's Tax Credits & Transferability 2026

Carl J. Fleming is the global co-head of our Energy & Project Finance Group, ranked by Chambers as one of the industry’s leading energy practices. He is a trusted legal, commercial, and strategic advisor whose principal areas of practice are energy, digital infrastructure, and critical minerals.

In addition to his transactional work, Carl is also a sought-after policy advisor, having previously served as a direct advisor to the White House and now as a private sector appointed advisor to the Trump 47, Biden, Trump 45, and Obama White Houses. He has led a number of cutting-edge policy and transactional matters for the US government across the energy, digital infrastructure, and critical mineral sectors.

Chambers lists Carl among the best individual energy and infrastructure lawyers in the United States, ranking him for Projects: Power & Renewables: Transactional. Clients reporting to Chambers state that “Carl is exceptionally attentive and proactive with clients.” He is also recognized by Legal 500 as a “Leading Lawyer” for Energy: Renewable/Alternative Power. Additionally, Super Lawyers ranks him as one of the “top 5% of attorneys” globally.

Carl leads a Chambers-ranked team of more than 50 dedicated energy and infrastructure lawyers, one of the largest energy and infrastructure practices in the world. Together, the team guides his clients through the industry’s most sophisticated and headline-grabbing transactions in the US and worldwide. His clients include leading energy developers, prominent data center developers, private equity funds, private credit funds, investment banks, and Fortune 500 companies.

Since the adoption of the Inflation Reduction Act (IRA) and the subsequent One Big Beautiful Bill Act (OB3), Carl and his Energy & Project Finance Group have closed more than 350 post-IRA and OB3 tax credit driven transactions, surpassing the rest of the industry. These include several “first-in-kind” hybrid tax equity investments, tax credit transfers, preferred equity investments, cash equity investments, and debt financings. He and his team have also helped several clients through the energy industry’s “grand re-think” of the finance markets post-IRA and OB3.

Carl’s work and thought leadership are often featured in leading publications such as The Wall Street Journal, The Financial Times, The Economist, Newsweek, Fast Company, The Washington Post, and Politico, among others. He is also frequently interviewed for his market insights by global media outlets such as Reuters, Forbes, Bloomberg, BBC, and others. He has also been hosted on numerous podcasts, including the Fierce Network’s The Five Nine podcast.

Carl is a frequent speaker and prominent author. He was selected by the White House to address the global delegation at the 29th Annual United Nations Climate Change Conference (COP29) and speaks throughout the US and internationally. He focuses on topics such as energy, digital infrastructure, and critical minerals. He has written, or contributed to the writing of, several books or chapters on project finance. He has lectured at Harvard University, the Georgetown University Law Center, the University of Pennsylvania, and American University.

Carl is based out of the Washington, DC, and New York offices. He also works across our London, Paris, and Milan offices, among others.

As a member of the Corporate Department, Debra focuses her practice on renewable energy transactions, general corporate matters, franchising, licensing and distribution matters, as well as other business growth strategies.

Debra’s corporate practice includes counseling clients, both publicly and privately held, on transactions related to capital formation, mergers and acquisitions, reorganizations, brand extension programs, joint ventures and strategic alliances in a variety of industries. She has extensive experience advising clients on renewable energy transactions, including the structuring, development and financing of renewable projects throughout North America and Europe. Debra has served as counsel for major investment banking clients, large developers, sponsors, utilities, and other lenders and investors in the development, implementation, acquisition, structuring and financing of renewable assets, including the negotiation of acquisition and financing documents (including tax equity and back leverage), strategic investments, PPAs, EPCs, and various agreements related to state and local incentives and renewable energy credits.

Debra also counsels clients on distribution, franchise and dealer relations, terminations, transfers and regulatory compliance. Her experience includes mergers and acquisitions involving franchise systems, development of domestic and international franchise strategies, preparation of franchise and license agreements and related disclosure materials, advising on compliance programs and distributor consolidation matters, as well as franchisee and dealer terminations. She has worked with hundreds of franchisors and suppliers in a wide variety of industries, including energy, food service, retail, beverage (alcohol and non-alcohol), hospitality, automobile rental, convenience store, sports and entertainment, cosmetology, healthcare, real estate, industrial goods, clothiers, cosmetics, and residential and light commercial services.

Debra has served as pro bono counsel to the National Association of Women Business Owners, coordinates the Firm’s staffing of, and regularly volunteers at the D.C. Bar’s Landlord Tenant Resource Center, and has provided pro bono legal assistance to multiple charitable organizations, including FAIR Girls, No One Left Behind, UNITAS, the Human Rights Campaign and the Northern Virginia Coalition.

Seth Doughty focuses his practice on transactional matters in the energy industry with a special emphasis on power procurement, tax equity financing, and build-transfer agreements. He has a focused interest in energy storage projects and is a co-author of the United States’ Department of Commerce’s forthcoming Understanding Energy Storage handbook.

In the power procurement area, Seth has drafted and negotiated a wide variety of power purchase agreements, contracts for differences, and other purchase and sale agreements, including for energy, capacity and resource adequacy, renewable energy credits, energy efficiency and distribution deferral products. He is experienced in handling procurement of offtake from conventional, renewable and energy storage technologies for both the “in-front-of-the-meter” and “behind-the-meter” projects. He has represented utilities, developers, and corporate buyers in regulated and unregulated markets.

In the tax equity space, Seth has acted for Sponsors and Tax Equity Investors in nearly 3 gigawatts of tax equity investments for solar, wind, and hybrid energy storage projects throughout the United States. He has represented either the purchaser or the seller in build-transfer agreements relating to over 3 gigawatts of solar, wind and battery storage capacity in regulated and unregulated spaces.

Prior to joining the firm, he worked in-house at one of the largest Southern California utility companies. There, he gained experience drafting and negotiating a variety of power procurement agreements and valuable insights about utility customers.

While in law school, Seth was a senior editor for the Southern California Law Review.