Second Annual REITs, MLPs and YieldCos Webinar An Update on REITs, MLPs and YieldCos
Thursday, September 4, 2014:
1:00 - 2:30 pm Eastern US Time
The United States renewable energy industry is abuzz with talk of REITs, MLPs and YieldCos. This panel will explain what these three vehicles are, how they can be deployed under current law and initiatives to expand their application.
The panel will explain the fundamental principle to understanding these vehicles: if an entity’s equity is publicly traded, the entity must in most instances be taxed as a corporation (i.e., a “c” corporation). Being taxed as a corporation means the imposition of two layers of tax: the entity pays tax and its shareholders pay tax on dividends and gains from the sale of the stock. This general rule applies even if the entity takes the state law form of a limited partnership, a limited liability company or a trust. The REIT and MLP rules are special exceptions to this principle.
REITs and MLPs are able to be publicly traded while avoiding the entity layer of tax. Thus, they are the holy grail of corporate finance: relatively low cost and highly liquid capital from retail investors with a single layer of tax. In contrast, a YieldCo is an entity that is publicly traded, taxed as a corporation but that plans to manage its tax position to limit the tax it and its shareholders incur.
The panel will explain how each of these three investment vehicles can be used for renewables under current law; however, REITs and MLPs are subject to difficult tax limitations which will be discussed. The discussion will include analysis of recently proposed REIT regulations that permit distributed generation solar in a narrow fact pattern to qualify as a REIT asset.
The panel will explain that YieldCo is a publicly traded corporation that intends to manage its tax profile and it is not seeking to satisfy any particular definition in the Internal Revenue Code. YieldCos have been launched by NRG and Abengoa. NextEra and SunEdison are working on launching YieldCos. SunPower and Acciona/KKR have communicated that they are considering them. The panel will highlight investment banking rules of thumb for a YieldCo IPO.
David K. Burton, Partner, Akin Gump Strauss Hauer & Feld LLP
Amit Kalra, Partner, Winston & Strawn LLP
Eli M. Katz, Partner, Chadbourne & Parke LLP
How It Works
Single Connection: $245.00
Additional Connection at the same Organization: $150.00
A site connection allows a single connection to the web conference. That connection is open to any number of users in a collaborative setting. Because there are no travel expenses and only a single registration fee is required, each additional participant lowers the cost per participant significantly.
By purchasing a site connection, you can invite as many people as you would like to view and participate in the session from a single location. Set up the session in a conference room and project the presentation and chat on a large screen. You also have rights to distribute copies of the presentation materials to everyone involved. Please note that audio is received via the phone line and must be broadcast to your group.
If for any reason a relevant stakeholder cannot co-locate for the session, we encourage you to include that person by purchasing an additional connection at the reduced fee of $150 per session. This will ensure that every member of a team receives the same relevant, timely information in the most efficient way. If you have any technical or purchasing questions, please contact us at (818) 888-4444.
CANCELLATION, REFUNDS & CREDITS
Should you be unable to attend, a refund, less a $50 administrative charge, will be made for cancellations received via letter or fax at least 3 working days before the event. We regret cancellations will not be accepted after that date. However, we will be pleased to transfer your registration to another member of your company or credit the registration fee to another Infocast conference if you register within 6 months from the date of this conference. In the event the conference is canceled, Infocast’s liability is limited to the refund of the conference registration fee only.