John Eliason has built a distinguished career and longstanding relationships by providing tax, legal, and business advice to financial institutions, private equity funds, developers, owners, and equipment manufacturers in the real estate, energy, and infrastructure sectors. Currently, he serves as co-chair of Foley’s Energy Industry Team.
John focuses his practice primarily in the renewable energy space, concentrating on wind, solar, biomass, and other emerging technologies that rely on federal and state tax incentives, like the Federal production tax credit (PTC), energy investment tax credit (ITC), and accelerated depreciation (MACRS and “bonus”). He is versed in unlocking the value of those tax benefits for transaction participants using partnership flips, public/private partnerships, sale-leasebacks, prepaid PPAs, and other structuring options. John regularly advises non-U.S. based pension and private equity funds investing in energy and infrastructure assets. He also represents clients in front of the Department of Treasury and the Internal Revenue Service.
John’s practice also concentrates on tax-deferred investments made in qualified opportunity zones, pursuant to a federal program enacted into law in December 2017 as part of the Tax Cuts and Jobs Act. In this area, he represents both investors and equity funds navigating section 1400Z of the Tax Code (and the related regulatory and administrative guidance applicable to the opportunity zone legislation) and advises on compliance-related matters.
John began his legal career with Hunton & Williams LLP, focused on the tax side of equipment and other “big ticket” leasing transactions. Following that, he practiced with Gardere Wynne Sewell LLP, focused on partnership tax, formations, and structuring opportunities for energy and real estate development clients.
Prior to practicing law, John founded an information management company based in Austin, Texas. He is also a veteran of the Texas Army National Guard.
Representative Experience
Recognition
John is nationally ranked by Chambers USA in the area of renewables & alternative energy (2018 - 2020). John also has been recognized by The Legal 500 for his work in project finance and energy: renewable/alternative. He is a recipient of Foley’s Carl Hitchner "Mentor of the Year Award," presented annually to recognize outstanding mentoring to our young attorneys.
Education
John earned an LL.M. in taxation from New York University School of Law and graduated with a J.D. from Washington and Lee University School of Law. He completed his B.A. in economics at The University of Texas at Austin.
Admissions
John is admitted to practice in the District of Columbia, New York and Texas.